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2022 (2) TMI 1278 - AT - Income TaxReopening of assessment based on revenue audit objection - HELD THAT:- Reasons recorded never disclosed that reopening based on audit objection. Assessee submits that even the assessee has good case on merit and without going into controversy whether case is covered by exception clause of CBDT Circular or not he is ready to contest the appeal on merit and he has no objection if the order 15.04.2021 is re-called and the appeal is heard on merit. Considering the concessions on the assessee that he is ready to argue the appeal on merit, the order dated 15.04.2021 is recalled and the appeal is fixed for hearing on merit on 31.03.2022. Issuance of separate notice is dispensed with as the date of hearing was fixed with the consent of both the parties. Miscellaneous Application filed by the Revenue is allowed.
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