9911796707
TMI Blog2019 (10) TMI 1301X X X X Extracts X X X X X X X X Extracts X X X X ..... s is an appeal filed by the assessee against the order of the ld CIT(A), Rohtak dated 30.08.2018 for the Assessment Year 2009-10. 2. The assessee has raised the following grounds of appeal:- "1. The Ld. CIT(A) has erred in law and on facts in upholding the reopening of the assessment u/s l47/148. which is bad in law and liable to be quashed. 2. The Ld. CIT(A) has erred in law and on facts in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of recording the reasons, assessee has earned profit from client code modification creating non genuine loans of Rs. 39852/-. Hence, notice u/s 148 was issued. The assessee did not furnish any return of income in response to that notice. Subsequently, notice u/s 142(1) as well as 143(2) was issued. The Assessee has shown the profit of Rs. 186954/- whereas, the total income of the assessee was ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rom Investigation Wing only. He further submitted that the date of return of income has also been wrongly mentioned by the assessee as it was originally filed on 27.03.2010 but the AO mentioned it as 07.07.2009. He further stated that income was recorded at Rs. 183110/- by the ld AO whereas, the Assessee filed the return of income at Rs. 276690/-. He further stated that the working of the figure o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... with due application of mind, properly approved hence, correctly initiated. It was further submitted that there is no evidence submitted by assessee. 6. We have carefully considered the rival contentions and perused the orders of the lower authorities. Admittedly, in this case the assessee has filed her return of income on 27.03.2010 whereas the ld AO has mentioned that same was filed on 07.07.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Vs. RMG Polyvinyl (I) Ltd. In this case the specific information such as date of return, amount of income returned and whether the escapement of income is provided or loss has not at all been verified by the ld AO. In view of this on the above reasons recorded by the ld AO, we do not upheld the reassessment proceedings initiated by the ld AO thus, on the issue of reopening u/s 147 of the Act, we r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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