TMI Blog2012 (1) TMI 266X X X X Extracts X X X X X X X X Extracts X X X X ..... e cross appeals filed against the order of the learned CIT(A)-XVI, Ahmedabad for Assessment Year 2003-04. 2 The assessee has raised various grounds in its appeal. The first ground raised by the assessee reads as under:- 1. The ld. CIT(A) has erred in law and on facts in upholding the order without appreciating the facts that during course of assessment hearings, no discussion of various ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es have become settled and attained finality, more particularly the system of accounting. The system of accounting consistently followed by the assessee for last many years, so to say since inception with regard to maintenance of stock records, and other records have been accepted by the department, for certain years additions for alleged non-maintenance of records for consumption of raw mate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l the details as required including quantity details of goods produced, raw materials consumed and details of expenses have been given. It is also pertinent to point out that during course of hearings, only the submissions were received but no discussion was made and the assessee was appraised as to whether the Assessing Officer is satisfied with the details furnished or not or any further de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aring, the learned counsel of the assessee submitted that the AO has passed the order without giving proper opportunity of being heard to the assessee, as he took the assessment proceedings at the fag end of the year when the case was getting time-barred. He accordingly prayed that in the interest of justice and fair play, the mat ter may be restored to the file of the AO for re-adjudication. 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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