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1995 (2) TMI 368

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..... d for reopening of the assessment, the basis shown was a report of the audit objection. Except that no other material was brought to the notice of the assessee. The assessee objected to the reopening, inter alia, stating that the audit objection cannot be the basis for reopening the assessment. It is also pointed out that inasmuch as the jurisdiction was challenged, the petitioner did not raise an .....

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..... cts to the very initiation of the revision of the assessment under section 19. Though opportunities were given, the opposite party has not taken steps to file counter-affidavit. However, learned Government Advocate argued the matter contending that the assessing officer has jurisdiction to pass order under section 19 of the Act and if at all the petitioner has a remedy to file appeal as provided .....

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