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2012 (4) TMI 626 - AT - Income TaxWhether CIT(A) has erred in deleting the addition made on account of forfeiture of shares despite the fact that the amount was a Revenue receipt which the assessee had omitted to show as an income? - HELD NO Whether CIT(A) has erred in holding that the issue of notice u/s 148 is barred by time limit despite the fact that the Assessing Officer has issued notice within the time limit? - HELD YES - CIT(A) has not given any findings to this effect that there was no failure on the part of the assessee to make a return u/s 139 or in response to a notice under sub section to section 142 or section 148 or to disclose fully and truly all material facts necessary for assessment for that assessment year. In absence of such findings, the CIT(A) was not justified in holding that the notice issued u/s 148 was barred by limitation. In view of the above, we allow this ground of appeal.
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