TMI Blog2017 (9) TMI 1465X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 143(3)? - Held that:- In the first place, question (i) was not raised by the Revenue in its appeals before the Income-tax Appellate Tribunal. Secondly, the fact remains that the Revenue chose the route of section 153A of the Act to proceed against the assessee. Having chosen that route, there had to be some incriminating material qua the assessee to justify the initiation of proceedings thereu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rns "N" Petals [2017]. Therefore, the court is not inclined to frame question (ii) as urged by the Revenue. - I. T. A. Nos. 487, 488 and 489 of 2017 - - - Dated:- 10-7-2017 - Dr. S. Muralidhar And Prathiba M. Singh, JJ. For the Appellants : Rahul Chaudhary, Senior Standing Counsel with Lakshmi Gurang, Advocate For the Respondent : Piyush Kaushik, Advocate JUDGMENT CM Nos. 23 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mation sent under section 143(1) for the assessment years 2002-03 to 2004- 05 fall in the category of completed assessments when there was no assessment made under section 143(3) ? (ii) Whether on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in deleting the additions made in the assessment orders for the assessment years 2002-03 to 2004-05 on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nding counsel for the Revenue that in all these three assessment years, the returns filed by the assessee were not picked up for scrutiny and only an intimation was sent under section 143(1) of the Act. She contends that there was no completed assessment for the said three assessment years. She submitted that the said assessments should be treated as pending assessments in respect of which proce ..... X X X X Extracts X X X X X X X X Extracts X X X X
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