TMI Blog2020 (6) TMI 244X X X X Extracts X X X X X X X X Extracts X X X X ..... sultant assessment orders. - Decided in favour of assessee. - ITA No.328/PUN/2017, ITA No.1794/PUN/2019, ITA No.1789/PUN/2019, ITA No.1800/PUN/2019, ITA Nos.1802 & 1803/PUN/2019 - - - Dated:- 9-6-2020 - Shri R.S. Syal, Vice President For the Appellant : Shri Sunil Ganoo For the Respondent : Ms. Nishtha Tiwari And Shri Prathamesh J.Lawand ORDER PER R.S.SYAL, VP : These six appeals by different but connected assessees arise out of separate orders passed by the CIT(A)-1, Kolhapur on different dates for the captioned years. Since all these appeals are based on similar facts and involve common issue, I am, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience. 2. ITA No. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... remained unsuccessful before the ld. CIT(A), which has led to filing of the instant appeal before the Tribunal. 5. I have heard both the sides and gone through the relevant material on record. A copy of reasons recorded, available at page 8 of the paper book, deciphers the reasons as under: According to information gathered from informed sources, local enquiries and media reports, it has come to be known that Shri Kanhaiyalal Gidwani, owns three flats, one in his name and two in the names of his two sons Kailash and Amit in the Adarsha Housing Society. Again, one flat is learned to be booked in the name of Shri Gajanan S. Koli, where apparently it is believed that Shri Sunil K. Gidwani, son of Kanyiyalal Gidwani, has lent finance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s para does not refer to any specific escapement of income. It is the second para with reference to the escapement of income towards difference in closing capital as on 31.03.2007 and opening balance leading to difference of ₹ 47,093/-. That is how the AO concluded at the end of the reasons that : `I have reasons to believe that the income chargeable to tax to the extent of ₹ 47,093/- [1802863 1849906] escaped assessment within the meaning of Section 147 of the I.T. Act, 1961. Thus, it is evident that the re-assessment was initiated on account of difference in capital to the tune of ₹ 47,093/-. On scrutiny of the assessment order, it transpires that the AO did not make any addition on this score. Thus, it is apparent th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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