TMI Blog2014 (11) TMI 1203X X X X Extracts X X X X X X X X Extracts X X X X ..... light of the decision of the Hon ble Gujarat High Court SAHKARI KHAND UDYOG MANDAL LTD. VERSUS ASSTT. COMMISSIONER OF INCOME TAX [ 2014 (6) TMI 149 - GUJARAT HIGH COURT] relied upon by the assessee, we are of the view that the copy of the reasons recorded while reopening the assessment u/s 147 has to be issued to the assessee, and accordingly, the issue in the grounds of the appeal of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : 1. The ld.CIT(A) erred in fact and in law in confirming the action of the AO in invoking the provisions of section 147 for reopening the assessment and consequently making the assessment u/s.147 r.w.s. 143(3) of the Act. 2. The ld.CIT(A) erred in fact and in law in rejecting the claim of the appellant that no reasons were provided by the AO for the purpose of reopening of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AO in making disallowance of Director s remuneration paid to Smt. Induben P. Mehta, ₹ 72,000/- p.a. and ₹ 75,000/- paid to Smt. Trapti N. Mehta. 3. The learned counsel for the assessee submitted that the action of the AO in invoking the provision of section 147 for reopening of the assessment is bad in law, as the assessee was never served with the copy of reasons recorded b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner of Income-tax, 44 taxmann.com 397 (Bom). 5. We have considered rival submissions. We find that the assessee has requested in its written submissions before the CIT(A) for copy of reasons recorded by the AO while reopening assessment under section 147 of the Act, and the same were not given to the assessee. In these facts and in the light of the decision of the Hon ble Gujarat High ..... X X X X Extracts X X X X X X X X Extracts X X X X
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