TMI Blog2013 (3) TMI 686X X X X Extracts X X X X X X X X Extracts X X X X ..... r:- Both appeals filed by the assessee are directed against two separate orders of Commissioner of Income-tax, Ahmedabad-III ( CIT for short) both dated 17-01-2012 passed by him u/s. 263 of the Income-tax Act, 1961 (hereinafter referred to as the Act ) pertaining to assessment year (AY) 2007- 08 and 2008-09 respectively. 2. Although the assessee has raised various grounds in both the yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment proceedings, the order of Ld. CIT is justified. 4. We have considered the rival submissions, perused the materials available on record and gone through the orders of authorities below. We find that a clear finding is given by Ld. CIT in his order of both the years that the Assessing Officer failed to apply his mind to all aspect of the case and he has also given a finding that AO pass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cation of his mind. Ld. CIT has simply directed the AO to pass a fresh assessment order after calling for all the necessary details along with detailed explanation of the assessee and after making the requisite inquiry bringing all relevant facts on record and after having applied his mind to all aspect of the case. In the facts of the present case, we by respectfully following the judgment of Hon ..... X X X X Extracts X X X X X X X X Extracts X X X X
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