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INCOME TAX APPELLATE TRIBUNAL (JAIPUR BENCH)
RATHOD KAMLESH JAYANTBHAI, AM
M/s Shivam Readymix P. Ltd. – Appellant
Versus
Commissioner of Income Tax (Appeals), Jaipur -4 – Respondent
| Table of Content |
|---|
| 1. the appeal is regarding reopening of assessment based on unaccounted purchases. (Para 1 , 3) |
| 2. issues of jurisdiction and procedure under relevant income tax sections. (Para 2 , 5) |
| 3. the final ruling indicating the appeal's allowance and basis for the decision. (Para 4) |
ORDER
PER: RATHOD KAMLESH JAYANTBHAI, AM
The present appeal is filed by the assessee aggrieved from the order of the order of the Commissioner of Income Tax (Appeals), Jaipur -4 [here in after ld. CIT(A) ] dated 23/01/2025 for assessment year 2012-13. The said order of the ld. CIT(A) arises as against the order dated 31.12.2019 passed under section 147 r.w.s 143(3) of the Income Tax Act, 1961 [ for short Act] by ACIT, Central Circle-03, Jaipur.
2. In this appeal, the assessee has raised following grounds: -
1. On the facts and in the circumstances of the case and in law, Id. CIT(A) has grossly erred in confirming the actions of ld. AO in re-opening the case u/s 147 of the Income Tax Act, 1961 arbitrarily.
1.1 On the facts and in the circumstances of the case, Id. CIT(A) has grossly erred in not appreciating the fact that the reason recorded on the basis of which case was reopened and the order passe
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