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INCOME TAX APPELLATE TRIBUNAL (RAJKOT BENCH)
Dr. Arjun Lal Saini, AM, Shri Dinesh Mohan Sinha, JM
Sidique Ibrahim Allana – Appellant
Versus
Assistant Commissioner of Income Tax (International Taxation) – Respondent
| Table of Content |
|---|
| 1. assessment appeal filed regarding reopening. (Para 1 , 2) |
| 2. factual background of the case. (Para 3 , 4 , 5 , 6 , 7) |
| 3. findings of the dispute resolution panel. (Para 8 , 9) |
| 4. arguments by the assessee's counsel. (Para 12 , 13 , 14) |
| 5. arguments on technical issues regarding reopening. (Para 16 , 17) |
| 6. court's analysis on evidentiary value. (Para 18 , 19 , 20 , 21 , 22) |
| 7. legal principles regarding admissibility of evidence. (Para 23) |
| 8. final conclusion and order. (Para 24 , 25 , 26) |
आदेश / ORDER
Captioned appeal filed by the Assessee, pertaining to assessment year (A.Y.) 2013-14, is directed against the final assessment order passed by the Assessing Officer, dated 31.12.2024, after incorporating the directions of the Dispute Resolution Panel (in short “DRP”), vide DRP order dated 29.11.2024, under section 144C(5) of the Act.
“1.The Assessing Officer erred in reopening the assessment by issue of notice u/s 148 of the Act. The reopening of the assessment was barred by limitations of time.
3.Without prejudice to ground no. 1 and 2, the Assessing Officer erred in making an addition of Rs. 5,50,00,000 (Rs. Five Crores Fifty Lakhs) to the income under the provisions of sec
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