2018 (12) TMI 470

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..... pondent. P.C.: 1. Since appeals arise out of the common judgment of income Tax Appellate Tribunal and involve identical issues, we have taken upon board Income Tax Appeal No.820 of 2016 alongwith Income Tax Appeal No.766 of 2016, which is on board. Since issues are common, we may notice facts from Income Tax Appeal No.766 of 2016 for the Assessment Year 2008-09. Revenue has challenged the judgme .....

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..... the source and application of funds, which was found to be for nonbusiness purposes, and instead accepting the contention of availability of free funds, for which there is no direct link/evidence?" 2. From the perusal of the questions, we can gather that the first issue pertains to the question of validity of the proceedings of reassessment. The second question pertains to the merits of the disa .....

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..... form a reasonable belief that income chargeable to tax has escaped assessment or he was proceeding entirely on borrowed satisfaction would have to be examined in light of the reasons recorded by the Assessing Officer. In the present case, however, we are not inclined to undertake minute scrutiny of such reasons and other related material on record. This is so because we are convinced that on meri .....

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