YOGENDRAKUMAR RAMAVTAR AGARWAL,SURAT vs. ITO, WARD-1(2)(1), SURAT

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Yogendrakumar Ramavtar Ito, Ward-1(2)(5), Agarwal, Surat Current Jurisdiction: 2053-Mahaveer Textile Market, Vs. Ito, Ward 1(2)(1), Ring Road, Textile Area, Aayakar Bhavan, Near Majura Surat-395002. Gate, Opp. New Civil Hospital, Surat-395001 Pan No. Aarpa 7623 C Appellant Respondent

unexplained investment u/s. 69 of the I.T. Act. investment u/s. 69 of the I.T. Act. 4. It is therefore prayed that above assessment framed 4. It is therefore prayed that above assessment framed 4. It is therefore prayed that above assessment framed u/s. 147 may kindly be quashed and/or the u/s. 147 may kindly be quashed and/or the additions additions

JITENDRAKUMAR AMBELAL PATEL,NA vs. ARIVS.ITO, WARD-3, NAVSARI

In the result, the appeal of the assessee is partly allowed for e appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Jitendrakumarambelal Patel Ito, Ward-3, 52, Kanbiwad. At & Po-Pananj, Room No. 108, Swapnalok Soc., Tal-Chikhli, Navsari-396521 Vs. Near Kaliawadi Bridge, Navsari - 396521 Pan No. Bncpp 7509 R Appellant Respondent

unexplained investment. 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income law on the subject, the learned Commissioner of Income law on the subject

SURESHBHAI RAGHUBHAI THORAT,VALSAD vs. ITO, WARD-7, VAPI

In the result, the appeal of the assessee is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.426/Srt/2024 (Assessment Year: 2017-18) (Physical Hearing) Sureshbhai Raghubhai Thorat, Vs. The Ito, Siddharth Villa, At Post Ozar, Ward – 7, Mota Pondha B.O., Valsad – Vapi 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acapt3507F (Appellant) (Respondent) Appellant By None Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 02/01/2025 Date Of Pronouncement 03/01/2025

reassessment proceedings u/s 147 r.w.s. 144 of the Act on the basis of invalid notice issued u/s 148 of the Act. 4) The ld. CIT(A) has erred in law and on facts in upholding, without adjudication, the action of ld. ITO of completing the assessment u/s 144 of the Act in defiance principles of natural justice, equity and fairness

DHAVAL INDRAVADAN GANDHI,SURAT vs. ITO, WARD 2, BARDOLI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Shri Dhaval Indravadan Gandhi, Ito Ward-2, At & Post Areth, Tal Mandvi, Aayakar Bhavan, Janta Nagar Surat-394160. Vs. Society, Bardoli-394601. Pan No. Ajjpg 4246 J Appellant Respondent

147 of the I.T. Act, 1961 which is incomplete and also bad on facts. ITA No. 601/SRT/2025 2 Shri Dhaval Indravadan Gandhi Shri Dhaval Indravadan Gandhi 1.0(b) Without prejudice to above ground that on facts and in 1.0(b) Without prejudice to above ground that on facts and in 1.0(b) Without prejudice to above ground that on facts

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

u/s 147 of the Act, the submission and the various decisions of the Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which is reproduced below: 183 to 185/SRT/2021/AYs.2011-12 & 2012-13 Damodar

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

u/s 147 of the Act, the submission and the various decisions of the Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which is reproduced below: 183 to 185/SRT/2021/AYs.2011-12 & 2012-13 Damodar

JASODADEVI RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WD.-2(2)(2), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

u/s 147 of the Act, the submission and the various decisions of the Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which is reproduced below: 183 to 185/SRT/2021/AYs.2011-12 & 2012-13 Damodar

MAHOTSAV CREATION PVT. LTD.,SURAT vs. PR. COMMISSION OF INCOME TAX, -1,, SURAT

In the result, Both the appeals filed by the assessee are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.49 & 50/Srt/2021 Assessment Years: (2010-11 & 2011-12) (Virtual Court Hearing) Mahotsav Creation Pvt. Ltd., Vs. Principal Commissioner Of 101-102, 1St Floor, Sakar Textile Income-Tax-1, Aayakar Bhawan, Market, Ring Road, Surat-395002. Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaecm2394Q (Appellant) (Respondent) Assessee By Shri Hardik Vora, Advocate Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 28/06/2022 22/08/2022 Date Of Pronouncement

unexplained cash credit. Relevant portion is reproduced below for your Honours reference: "If share application money is received by assessee-company from alleged bogus shareholders, whose names are given to Assessing Officer, then Department is free to proceed to reopen their individual assessments in accordance with law but this amount of share money cannot be regarded as undisclosed income under

MAHOTSAV CREATION PVT. LTD.,SURAT vs. PR. COMMISSION OF INCOME TAX, -1,, SURAT

In the result, Both the appeals filed by the assessee are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.49 & 50/Srt/2021 Assessment Years: (2010-11 & 2011-12) (Virtual Court Hearing) Mahotsav Creation Pvt. Ltd., Vs. Principal Commissioner Of 101-102, 1St Floor, Sakar Textile Income-Tax-1, Aayakar Bhawan, Market, Ring Road, Surat-395002. Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaecm2394Q (Appellant) (Respondent) Assessee By Shri Hardik Vora, Advocate Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 28/06/2022 22/08/2022 Date Of Pronouncement

unexplained cash credit. Relevant portion is reproduced below for your Honours reference: "If share application money is received by assessee-company from alleged bogus shareholders, whose names are given to Assessing Officer, then Department is free to proceed to reopen their individual assessments in accordance with law but this amount of share money cannot be regarded as undisclosed income under

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

investment on purchase of\nvarious lands. The Assessing Officer has not examined the seller of land. There is no\nfinding of Assessing Officer whether the consideration paid by assessee was not in\naccordance with Jantri rate or less than the value determined by the Stamp Valuation\nAuthority. It is settled law that no addition on estimation basis can be made

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

In the result, assessee's appeal is allowed

reassessment proceedings, if the twin\nconditions prescribed under Section 147 of the Act are satisfied.\n23. In fact, in three recent judgments; the Hon'ble Gujarat High Court has upheld\nthe reopening on similar facts. The case is squarely covered against the assessee by\nthese judgments which are:\n•\nYogendrakumar Gupta vs. ITO 366 ITR 186 (Guj)\n•\nPeass Industrial

PREMJIBHAI AVCHARBHAI DALSANIA,NA vs. ARIVS.ITO, WARD-4, NAVSARI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.70/Srt/2020 ("नधा"रणवष" / Assessment Years: (2009-10) (Physical Court Hearing) Premjibhai Avcharbhai Dalsania, Vs. The Ito, Ward-4, 4, Shiv Shakti Soc. No.2, Shantadevi Navsari. Road, Navsari-396445, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ajbpd0551H (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri J. K. Chandnani, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 13/05/2022 घोषणाक"तार"ख/Date Of Pronouncement : 22/07/2022 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2009-10, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), [In Short ‘Ld. Cit(A)’] Valsad, In Appeal No. Itba/Apl/S/250/2019-20/1025203327(1) Dated 14.02.2020, Which In Turn Arises Out Of An Order Passed By Assessing Officer U/S 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As The ‘Act’).

147 after issuing notice u/s 148 of the Act and passing the reassessment order which is bad in law. 2. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in partly confirming the action of assessing Officer by sustaining the addition of Rs.5,00,000/- out of total

THE ASSTT. COMMISSIONER OF INCOME TAX, NA vs. ARI CIRCLE,, NAVSARIVS.SHRI KHEMCHANDBHAI KUNGMAL THARWANI,, NAVSARI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.2867-2869/Ahd/2016 (िनधा"रणवष" / Assessment Years: (2008-09 To 2010-11) (Virtual Court Hearing) Assistant Commissioner Of Income Shri Rajesh Khemchand Tharwani, Tax, Navsari Circle, Room L/H Lt. Shri Khemchandbhai Vs. No./302, Aaykar Bhavan, Nr. Kungmal Tharwani, Prop. Of K.K. Biscuit Bakery, 154-155, Gidc, Charpool Police Chowki, Kabilpore, Navsari-396445 Lunsikui, Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent) आयकरअपीलसं./Ita Nos.3135/Ahd/2016 (िनधा"रणवष" / Assessment Year: (2012-13) Shri Khemchand Kangumal Assistant Commissioner Of Income Tharwani, By L/R Rajesh Tax, Navsari Circle, Room No./302, Vs. Khemchand Tharwani, Prop. Of M/S Aaykar Bhavan, Nr. Charpool K.K. Biscuit Bakery, 154-155, Police Chowki, Lunsikui, Gidc, Kabilpore, Navsari-396445 Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent)

unexplained investment by the assessee. [6] Considering the facts stated above, I have reason to believe that the income of the assessee to the tune of Rs. 2,54,03,150/- for the accounting period relevant to A. Y. 2008- 09, has escaped assessment within the meaning of section 147 of the l.T. Act, 1961." 14. From the above reasons

THE ASSTT. COMMISSIONER OF INCOME TAX, NA vs. ARI CIRCLE,, NAVSARIVS.SHRI KHEMCHANDBHAI KUNGMAL THARWANI,, NAVSARI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.2867-2869/Ahd/2016 (िनधा"रणवष" / Assessment Years: (2008-09 To 2010-11) (Virtual Court Hearing) Assistant Commissioner Of Income Shri Rajesh Khemchand Tharwani, Tax, Navsari Circle, Room L/H Lt. Shri Khemchandbhai Vs. No./302, Aaykar Bhavan, Nr. Kungmal Tharwani, Prop. Of K.K. Biscuit Bakery, 154-155, Gidc, Charpool Police Chowki, Kabilpore, Navsari-396445 Lunsikui, Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent) आयकरअपीलसं./Ita Nos.3135/Ahd/2016 (िनधा"रणवष" / Assessment Year: (2012-13) Shri Khemchand Kangumal Assistant Commissioner Of Income Tharwani, By L/R Rajesh Tax, Navsari Circle, Room No./302, Vs. Khemchand Tharwani, Prop. Of M/S Aaykar Bhavan, Nr. Charpool K.K. Biscuit Bakery, 154-155, Police Chowki, Lunsikui, Gidc, Kabilpore, Navsari-396445 Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent)

unexplained investment by the assessee. [6] Considering the facts stated above, I have reason to believe that the income of the assessee to the tune of Rs. 2,54,03,150/- for the accounting period relevant to A. Y. 2008- 09, has escaped assessment within the meaning of section 147 of the l.T. Act, 1961." 14. From the above reasons

KHEMCHAND KANGUMAL THARWANI,,NA vs. ARIVS.THE ASSTT. COMMISSIONER OF INCOME TAX, NAVSARI CIRCLE,, NAVSARI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.2867-2869/Ahd/2016 (िनधा"रणवष" / Assessment Years: (2008-09 To 2010-11) (Virtual Court Hearing) Assistant Commissioner Of Income Shri Rajesh Khemchand Tharwani, Tax, Navsari Circle, Room L/H Lt. Shri Khemchandbhai Vs. No./302, Aaykar Bhavan, Nr. Kungmal Tharwani, Prop. Of K.K. Biscuit Bakery, 154-155, Gidc, Charpool Police Chowki, Kabilpore, Navsari-396445 Lunsikui, Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent) आयकरअपीलसं./Ita Nos.3135/Ahd/2016 (िनधा"रणवष" / Assessment Year: (2012-13) Shri Khemchand Kangumal Assistant Commissioner Of Income Tharwani, By L/R Rajesh Tax, Navsari Circle, Room No./302, Vs. Khemchand Tharwani, Prop. Of M/S Aaykar Bhavan, Nr. Charpool K.K. Biscuit Bakery, 154-155, Police Chowki, Lunsikui, Gidc, Kabilpore, Navsari-396445 Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent)

unexplained investment by the assessee. [6] Considering the facts stated above, I have reason to believe that the income of the assessee to the tune of Rs. 2,54,03,150/- for the accounting period relevant to A. Y. 2008- 09, has escaped assessment within the meaning of section 147 of the l.T. Act, 1961." 14. From the above reasons

THE ASSTT. COMMISSIONER OF INCOME TAX, NA vs. ARI CIRCLE,, NAVSARIVS.SHRI KHEMCHANDBHAI KUNGMAL THARWANI,, NAVSARI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.2867-2869/Ahd/2016 (िनधा"रणवष" / Assessment Years: (2008-09 To 2010-11) (Virtual Court Hearing) Assistant Commissioner Of Income Shri Rajesh Khemchand Tharwani, Tax, Navsari Circle, Room L/H Lt. Shri Khemchandbhai Vs. No./302, Aaykar Bhavan, Nr. Kungmal Tharwani, Prop. Of K.K. Biscuit Bakery, 154-155, Gidc, Charpool Police Chowki, Kabilpore, Navsari-396445 Lunsikui, Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent) आयकरअपीलसं./Ita Nos.3135/Ahd/2016 (िनधा"रणवष" / Assessment Year: (2012-13) Shri Khemchand Kangumal Assistant Commissioner Of Income Tharwani, By L/R Rajesh Tax, Navsari Circle, Room No./302, Vs. Khemchand Tharwani, Prop. Of M/S Aaykar Bhavan, Nr. Charpool K.K. Biscuit Bakery, 154-155, Police Chowki, Lunsikui, Gidc, Kabilpore, Navsari-396445 Navsari-396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalpt 1806 G (Assessee ) (Respondent)

unexplained investment by the assessee. [6] Considering the facts stated above, I have reason to believe that the income of the assessee to the tune of Rs. 2,54,03,150/- for the accounting period relevant to A. Y. 2008- 09, has escaped assessment within the meaning of section 147 of the l.T. Act, 1961." 14. From the above reasons

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

u/s 147 of the Act, the submission and the various decisions of the ITA Nos.552 & 882/SRT/2024 (A.Y.11-12) Rambilash R Jajoo & Sunita Jajoo Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

u/s 69B towards purchase of land at block No.7 and 287\nKumbharia, (ii) Rs.5,94,15,000/- u/s 69A on account of on-money receipt of\nKuberji Crown and (iii) Rs.55,00,000/- u/s 69B for unaccounted payment for land\nat plot No. 224 at Kumbharia.\n44.1 Aggrieved by the order of AO, the assessee filed appeal before

SUMITLAL,SURAT vs. ITO, SURAT

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Sumitlal, Ito 101-B/2, Sanskrut Flats Umra, Aayakar Bhavan, Bharthana, Vs. Surat-395007. Surat-395007 Pan No. Acxpl 1238 Q Appellant Respondent

reassessment ex parte ex parte under sections 147 read with 144 of the Act on 23.10.2017, treating the sections 147 read with 144 of the Act on 23.10.2017, treating the sections 147 read with 144 of the Act on 23.10.2017, treating the sum of ₹22,24,315/ 22,24,315/- representing the investment in mutual representing the investment in mutual