TMI Blog2010 (4) TMI 107X X X X Extracts X X X X X X X X Extracts X X X X ..... nce - petitioner submitted that after the said remand, assessment proceedings have not been completed and in view of Section 153(2A) of the Act, no assessment order can be passed because of limitation. Held that: This by itself does not merit discharge in the prosecution proceedings, which have been filed under Sections 276C and 277, i.e., willful attempt to evade income-tax and false verificati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Assessing Officer to go into the question of total quantum of addition, i.e., the valuation of shares which should not be less than Rs. 100/- per share. The said order passed by the Commissioner of Income-Tax dated 3rd January, 1995 cannot be construed as an order, which decides the controversy and the issue raised in the complaint on merits in favour of the petitioner. In the said order, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment year 1981-82 which, however, in the instant case should not be less than Rs.100/- per share, the actual sale consideration admitted by the appellant and as agitated by him in its alternative ground in this regard. I would like to mention that this assessment has been completed after the aforesaid directions were issued by the CIT (Appeals)IX. However, the assessment has been completed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s claimed by the accused. Later on 17th August, 2002, the accused in her letter to the I.T. Authorities had admitted that the sale of shares to be Rs.100/- per share. 3. Learned counsel for the petitioner submitted that after the said remand, assessment proceedings have not been completed and in view of Section 153(2A) of the Act, no assessment order can be passed because of limitation. This by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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