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TMI Blog2019 (10) TMI 743X X X X Extracts X X X X X X X X Extracts X X X X ..... None ORAL ORDER (PER : HONOURABLE MS.JUSTICE HARSHA DEVANI) 1. The learned advocate for the petitioner has tendered a draft amendment. Amendment is allowed in terms of the draft. The same shall be carried out forthwith. 2. Mr. B. S. Soparkar, learned advocate for the petitioner invited the attention of the court to the reasons recorded by the Assessing Officer for reopening of the assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mited and its Managing Directors and Directors. It was submitted that in the reasons recorded, Mr. Fenil Shah and Bharat Rasiklal Shah and Smt. Geetaben B. Shah are wrongly referred to as the directors of M/s. Satya Merchandise Private Limited. The attention of the court was invited to the list of directors of M/s. Satya Merchandise Private Limited, a copy whereof, is annexed along with the petiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... funds and disposed of the stock with dishonest and mala fide intention without adjusting the bank dues. It was submitted that, therefore, there is no basis for the findings referred to in paragraph 3 of the reasons recorded. 2.1 It was further pointed out that according to the Assessing Officer, substantial credit of Rs. 50,10,85,083/- in the bank account of M/s. Satya Merchandise Private Limite ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... corded, the Assessing Officer has observed that there are common directors between M/s. Satya Merchandise Private Limited and the beneficiary company whereas, there are no such common directors. It was submitted that, therefore, the reopening of assessment is also based on mere change of opinion. 3. It was urged that in the entire reasons recorded for reopening of assessment, there is no applica ..... X X X X Extracts X X X X X X X X Extracts X X X X
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