TMI Blog2012 (10) TMI 365X X X X Extracts X X X X X X X X Extracts X X X X ..... the ultimate purpose is to do justice. Even otherwise, no person should be condemned unheard and the CIT(A) has merely remanded the issue back to the file of AO, therefore, there is no justification to interfere with the order, the same is upheld. AO is directed to decide the issue afresh in accordance with law after providing due opportunity of being heard to the respective assesses. The asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax (A) on the ground that the impugned order is perverse and erroneous on facts and circumstances of the case. 2. The Department has raised as many as 4 grounds in these appeals to challenge the order of the Ld. Commissioner of Income Tax (A) in holding that the order passed by the Assessing Officer u/s. 200A of the Act was not appealable u/s. 246A and on the other hand directed the Assessing O ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee as applicable to the respective appeals, defended the impugned order by submitting that even if the appeal is not filed, still there is no grievance to the Revenue. 5. We have considered rival submissions and perused the material available on record. Before coming to a common conclusion, we are reproducing hereunder the relevant portion from the impugned order:- The above appeals are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g necessary notices u/s. 154 of the Act to the appellant and rectifying the orders as per law. If the rectification is not possible in computer, the Assessing Officer should manually rectify by passing suitable order in a format so that a mass rectification can be completed quickly. The AO (TDS) should give opportunity of being heard to the appellant before rectifying these orders and listening to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opportunity of being heard to the respective assesses. The assesses are at further liberty furnish evidence, if any, to substantiate their claim. Since the assesses have been granted fair opportunity, therefore, the time limit of completion within two months, as directed by the Ld. Commissioner of Income Tax (A), is withdrawn. However, the Assessing Officer is directed to complete within reasonab ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
