TMI Blog2021 (11) TMI 1142X X X X Extracts X X X X X X X X Extracts X X X X ..... ing has been found. It is also not the case that revenue has gotten the value of said premises independently valued to support the case of value more than that reflected in books. Assessee s plea of crossexamination has also been rejected. It is settled law that in allegation of on many payment , revenue is required to prove the case with convincing material. This proposition is supported by Hon b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment:- a. The learned CIT (A) - 3 erred in considering that Assessing Officer erred in reopening the Appellant's Assessment. b. He erred in reopening the assessment on the grounds that:- i. Based on information received from Dy.Director of Income Tax (Inv) the learned Assessing officer has reopened the Assessment u/s 143(3) r.w.s.147 of the I.T Act 1961. ii. ii. He e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ers Property Developers for purchase of shop No.12, at Sai Sugam and the payment of On-Money is reflected in the seized documents, Party Number-A-29, Bundle-2, Page 86 and 87 and further supported by the recorded statements u/s. 132(4) and 131 of the Act of the Directors of M/s. Ameya Builder and Property Developers. 4. The document seized was a paper maintained by the builder and not by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee is not based upon any incriminating material found from the assessee or his premises. It is also not the case that any material in assessee or its staff handwriting has been found. It is also not the case that revenue has gotten the value of said premises independently valued to support the case of value more than that reflected in books. Assessee s plea of crossexamination has also been reject ..... X X X X Extracts X X X X X X X X Extracts X X X X
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