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2002 (8) TMI 78 - HC - Income TaxRevision - Powers Of CIT - The revisional authority is, thus, under an obligation to consider and adjudicate on the relevant and material contentions which may be raised by an assessee. In the present case, we find that though the Director takes note of the stand of the assessee with regard to the status of each of the properties owned by the trust, he has not addressed himself to the real question, namely, whether in the prevailing circumstances any income could accrue to the petitioner from various properties. It is evident that the impugned order is too much influenced by the past non-cooperative conduct of the petitioner, be it on the merits of best judgment assessment or the quantum of income determined. At this juncture, we say no more on the merits of the case lest it may cause prejudice to either side.
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