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2022 (8) TMI 120 - AT - Income TaxReopening of assessment u/s 147 - Addition u/s 69 on account of unexplained investment - Case reopened on the basis of information received from Investigation Wing, Ahmedabad that a search action under Section 132 was carried out in case of Barter Group, Ahmedabad - HELD THAT:- The addition in the assessment order dated 27/09/2017 has no connection with the addition in assessment order passed under section 143(3)/147 dated 17/12/2018. The addition in the second assessment order dated 17.12.2018 is clearly based on the incriminating evidence about the investment in the share capital of M/s Rajendra Suri Financial Services (Gujarat) Pvt. Ltd. was found. We find that the assessee throughout the proceedings either before the Assessing officer or before the CIT(A) has shown a very casual approach and only submitted in pleading that the assessee was in the business of cheque discounting. The cheque discounting business was projected as ‘noble profession’ and as such no addition on account of unaccounted investment can be made. Thus, in absence of any evidence, we do not find any merit that grounds raised in the appeal is covered by the decision of Tribunal in assessee’s own case for A.Y. 2011-12 [2018 (9) TMI 1989 - ITAT SURAT]. Therefore, do not find any error or illegality in the order of the ld. CIT(A) and we uphold the same. - Decided against assessee.
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