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2022 (11) TMI 1207 - AT - Income TaxAO jurisdiction for conducting assessment proceedings as well as passing assessment order - change in the Assessing Officer of the similar rank - HELD THAT:- It can be seen that the assessee has filed return of income on 15.08.2015 with AO, Ward 7(1)(5), Ahmedabad, PAN No. of the assessee is AGKPT6559M and the notice which was issued by the respective ITO was also that of Ward 7(1)(5). Merely change in the Assessing Officer of the similar rank cannot be stated as not having jurisdiction for conducting assessment proceedings as well as passing assessment order. Therefore, all the contentions taken by the assessee which were incorporated in the original grounds of appeal as well in the revised grounds of appeal as well as the submissions before us does not stand at all in the eyes of law. Hence, all the contentions of the Ld. AR are rejected. Unexplained cash deposit and gift received from assessee’s wife as well as failed to prove genuineness of the other cash gifts - Documents produced during the assessment proceedings are not reflecting the source of cash deposits whether the gifts are genuine or not. At the time of hearing, the ld. AR has also not produced any additional evidence to that extent and also not demonstrated from whom the gifts were received and whether the gifts are genuine or not. Therefore, on merits the assessee’s case does not stand and, therefore, ground no.nil to the extent of merits in Column Nos.7, 8 & 9 stand dismissed Other grounds mentioned in original Form No.36 and in the revised grounds both are alleging the authorities in personal capacity which is uncalled act of the professional who is guiding his respective client i.e. assessee. Despite giving several opportunities to the Ld. AR, the Ld. AR was adamant to concise the grounds of appeal on the jurisdiction point as well as on merit point. The observation made hereinabove related to the jurisdiction point and merits should be taken into account as entirely deciding the appeal on merit as well as law. Appeal of the assessee is dismissed.
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