HARYANA PANEER BHANDAR Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS is an appeal by the Assessee against an order dated 21st July, 2014 passed by the Third Member and the consequential confirmatory order dated 8th December 2014 of the Income Tax Appellate Tribunal ('ITAT') in IT(SS) 26 & 33/Delhi/2010 for the block period 1st April, 1987 to 15th December, 1997.

(2.) ADMIT .

(3.) THE brief facts are that the Assessee is a partnership firm engaged in the business of manufacture and sale of paneer and snack items at Fateh Puri, Delhi. A search and seizure operation under Section 132 of the Act was conducted on 15th December, 1997 at the premises of one Mr. Kamal Chand Jain, wherein certain hundis as stated to have been issued by him were seized. It appears that the some of the hundis which purportedly pertained to the Assessee were forwarded by the Assessing Officer ('AO') of Mr. Jain to his counterpart having jurisdiction over the Assessee herein. Subsequently, the AO having jurisdiction over the Assessee recorded the reasons for reopening of the assessment and proceeded to issue a notice to the Assessee under Section 148 of the Act on 29th January, 2001.