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2017 (12) TMI 734 - AT - Income TaxReopening of assessment - no notice under section 143(2) have been issued - Held that:- In the present case, admittedly the AO issued notice under section 143(2) on 17th March, 2015 which have been served upon assessee and assessee participated in reassessment proceedings for year 2008-09. Therefore mere mistake in mentioning assessment year 2008-09 for filing of the return is not fatal to the case of the Revenue. Therefore not inclined to entertain the plea of the assessee that no notice under section 143(2) have been issued and served upon the assessee. The learned DR therefore rightly contended that this ground of appeal of assessee should be rejected. In view of the above discussion, this ground of appeal of assessee is rejected. Addition of sales - assessee submitted that it was a sale transaction without monetary consideration and in her alternate contention she has contended that the assessee being a house wife has no source of income - Held that:- The assessee has filed copy of the sale deed on record which clearly shows that assessee has paid ₹ 20,00,000/- to the seller/vendor in cash. Therefore, subsequent affidavits of deed writer, vendor and witnesses to the sale deed are not relevant and are clearly after thought and have been rightly rejected by the authorities below. The assessee failed to explain source of investment in purchase of property. All the contentions raised by the assessee have not been supported by any evidence or material on record. The case of the assessee is covered by judgment of Hon’ble Punjab and Haryana High Court in the case of Paramjit Singh (2010 (2) TMI 262 - PUNJAB & HARYANA HIGH COURT). The appeal of the assessee has no merit, the same is accordingly dismissed.
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