9911796707
TMI Blog2001 (3) TMI 244X X X X Extracts X X X X X X X X Extracts X X X X ..... our years with which we are dealing in this order. 2. As far as the asst. yrs. 1982-83, 1983-84 and 1984-85 are concerned, the original assessments were framed as under: --------------------------------------------------------- Asst. yrs. Income assessed Date of order and section of the IT Act --------------------------------------------------------- 1982-83 Rs. 2,08,000 under s. 143(3) dt. 3-3-1983 1983-84 Rs. 1,81,514 & ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 981-82, I will uphold the action of the AO in reopening these four assessments under s. 147(a) after getting necessary approval from the CIT. But on merits, I will restore the matter back to the file of the AO for fresh adjudication in the light of my observations contained in my order of even date in ITA No. 293/Asr/1991 in respect of asst. yr. 1981-82. 6. In the result, all the four appeals filed by the assessee are allowed for statistical purposes only. 28th Oct., 1993 &nbs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of asst. yr. 1981-82 the reassessments for the asst. yrs. 1982-83, 1983-84 and 1984-85 could not be sustained and thereby cancelling the same and ordering cancellation of reassessment order for the asst. yr. 1985-86 on the ground that transactions with M/s Ram Kumar Purshotam Dass, Jaitu, could not be said to be bogus, is justified or the approach adopted by the A.M. upholding the action of the AO in initiating proceedings under s. 147(a) of the IT Act, 1961, and restoring the matter back with regard to the genuineness of the loan transactions with M/s Ram Kumar Purshotam Dass to the file of the AO by relying on his dissenting order in ITA No. 293/Asr/1991 is correct?" 2. In this regard, it is seen that similar issue was decided by me in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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