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2022 (12) TMI 78 - ITAT SURATValidity of reopening u/s 147 - Reason to believe - case reopened on the basis of information gathered in the ITD system that assessee has made time deposit in IDBI Bank but no return of income was filed - HELD THAT:- As assessee neither before the AO nor before Ld.NFAC/CIT(A) and finally before me filed any submission or documents to substantive his case as to why the reopening is not valid. In my view, as assessee has not filed any return of income though assessee was given due opportunity before reopening by issuing query letter and seeking source of his investment. None of the notice / show cause notice or notice under section 148 was responded by the assessee. Therefore ground Nos. 1 and 2 of assessee are dismissed. Deposit in IDBI bank and State Bank of India - AO made both the additions in absence of any explanation or evidence produced by assessee. NFAC/CIT(A) granted partial relief with regard to deposit / credit in State Bank of India about the credit of salary. No other evidence to substantiate the source of investment filed nor any written submission is filed before me. Therefore, in absence of any explanation on the part of assessee, no merit in the ground No.s 3 & 4 raised by assessee
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