Court :
ITAT Bangalore
Brief :
These three appeals filed by the assessee are directed against different orders of CIT(A) for the above assessment years. The grounds in these appeals are common and there is only change in the figures in respect of different assessment years, which are as follows:
Citation :
ITA Nos.399 to 401/Bang/2020
IN THE INCOME TAX APPELLATE TRIBUNAL
“B’’ BENCH: BANGALORE
BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND
SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER
ITA Nos.399 to 401/Bang/2020
Assessment Year: 2010-11 to 2012-13
Sri Atul Dinesh Seth
No.10.2, Ibrahim Complex
S.P. Road
Bengaluru-560002
PAN NO : AFGPS6398E
Vs.
ITO Ward-2(3)(3)
Bengaluru
APPELLANT RESPONDENT
Appellant by : Shri Ravishankar S.V., A.R.
Respondent by : Shri Sunil Kumar Agarwal, D.R.
Date of Hearing : 04.03.2021
Date of Pronouncement : 08.03.2021
O R D E R
PER CHANDRA POOJARI, ACCOUNTANT MEMBER:
These three appeals filed by the assessee are directed against different orders of CIT(A) for the above assessment years. The grounds in these appeals are common and there is only change in the figures in respect of different assessment years, which are as follows:
1. The order of the learned CIT(A) in so far as it is against the Appellant is opposed to law, equity and weight of evidence, natural justice, facts and circumstances of the case.
2. The Appellant denies himself to be liable to a assessed to an income of Rs. 53,75,793/-under the facts and circumstances of the case.
Legal Grounds:
3. The learned CIT(A) failed to appreciate that the mandatory conditions to assume jurisdiction under section 148 does not exist and consequently the assessment made is bad in law on the facts and circumstances of the case.
4. The learned CIT(A) failed to appreciate that the reasons recorded by the learned assessing officer amounts to reason to suspect and do not amount to reason to believe on the facts and circumstances of the case.
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