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2022 (12) TMI 1317 - AT - Income TaxReopening of assessment u/s 147 - 2nd reassessment has been initiated even when the 1st assessment was due to be completed - two assessment orders have been passed by two different AO’s - unexplained investment u/s 69A on account of purchase of shares - HELD THAT:- In this case it is noted that two assessment orders have been passed by two different AO’s vide order dated 25-07-2019 and 8-12-2019 respectively. In the first assessment order dated 25-07-2019, the contentions of the assessee were accepted by the AO after due verification of the material on record. In the second assessment order dated 8-12-2019 u/s 144/147 of the Act, the AO made additions of Rs.3,41,360/- and Rs.3,59,000/- and added the same in the return of the assessee for the reason that the assessee did not submit the reply to the show cause notice issued by the new incumbent. In first appeal, the ld. CIT(A) deleted the additions against the order of the AO dated 8-12-2019 by observing that ‘’it is clear that the 2nd assessment order cannot stand the test of appeal and hence is annulled. The appeal of the assessee is allowed’’. Taking into consideration the above facts and circumstances of the case, we concur with the findings of the ld. CIT(A). Thus the appeal of the Revenue is dismissed.
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