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Income Tax Appellate Tribunal, BANGALORE BENCHES “A”, BANGALORE
Before: Shri George George K, JM & Shri B.R.Baskaran, AM
O R D E R
Per George George K, JM
This appeal was restored to the I.T.A.T. by the Hon’ble High Court in (judgment dated 23.02.2021). Before the Hon’ble High Court, there were four substantial questions of law for adjudication. The question of law 1 and 2 was regarding the issue on merits whereas the questions of law 3 and 4 were regarding validity of proceedings u/s 148 of the I.T.Act. The Hon’ble High Court in the above judgment, decided the issues raised on merits (ground No.1 and 2) in favour of the assessee. As regards the issue on jurisdiction for completing reassessment u/s 147 of the I.T.Act, the Hon’ble High Court restored the matter to the Tribunal (ground No.3 and 4).
When the matter had came up for hearing today, the learned AR submitted that the assessee is not pressing Initial Date 1. Draft dictated on 26.08.2021 Sr.PS 2. Draft placed before author 26.08.2021 Sr.PS 3. Draft proposed & placed before JM/AM the second member 4. Draft discussed/approved by JM/AM Second Member.
Approved Draft comes to the Sr.PS/PS Sr.PS/PS 6. Kept for pronouncement on Sr.PS 7. Date of uploading the order on website 8. If not uploaded, furnish the reason 8. File sent to the Bench Clerk Sr.PS 9. Date on which file goes to the AR 10. Date on which file goes to the Head Clerk.
Date of dispatch of Order.
Draft dictation sheets are Sr.PS attached