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Assessee has raised the ground that on the facts and circumstances of thecase, learned CIT(A) has erred, both on facts and in law in rejecting the contention of the assessee that the initiation of the reassessment proceedings and the reassessment order are bad, both on the facts and in law and liable to be quashed, as the statutory conditions and procedure prescribed under the statute have not been complied with.

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Sec. 147 & 148 of Income Tax Act, 1961—Reassessment- One turnover can be taxed in the hands of two different assessee one being partnership firm and another being proprietary concern of the assessee , therefore, AO is directed to delete the addition in the hands of the assessee to the extent of the turnover considered in case of partnership firm and since there is no change in the business model of the partnership firm as well as the business of the assessee, AO was directed to adopt the profit ratio of 8% as net profit on the gross receipts. - RAJESH GUPTA V/s ITO - [2020] 82 ITR (TRIB) 517 (ITAT-DELHI)