2010 (9) TMI 786

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... DGEMENT   The Income Tax Appellate Tribunal vide impugned judgment has set aside the notice of reassessment under Section 147/148 of the Act holding it to be bad in law and without jurisdiction. The order of the Tribunal reveals that while deciding this issue the Tribunal took up Ground of Appeal No.8 preferred by the appellant assessee relating to the validity of notice under Section 147/14 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... xpect the Tribunal, which is the highest fact finding authority in matters relating to taxation, to dispose of matters in such an offhanded and cavalier manner. In the instant case, we find that the Tribunal has effectively put an end to reassessment proceedings under Section 147/148 of the Act on the ground of invalidity of notice when such a plea was not raised by the assessee at all.   Fo .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X