9911796707
TMI Blog2007 (1) TMI 127X X X X Extracts X X X X X X X X Extracts X X X X ..... eferred for the opinion of this court by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short "the Tribunal"), arising out of the order passed in I. T. A. Nos. 609 to 613/ASR/84 in respect of the assessment years 1977-78 to 1981-82: "Whether, on the facts and in the circumstances of the case, the mistake occurred was not covered by the provisions of section 292B of the Act and i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal is as per the grounds of appeal. This was accompanied by photocopies of the grounds of appeal signed by the Commissioner of Income-tax, which were further even signed by the Inspecting Assistant Commissioner, who had signed the statutory Form No. 36. With this undisputed factual position on record still the Tribunal taking an extremely hyper-technical view held the appeals to be not valid. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in case the same is, in substance and effect, in conformity with or according to the intent and purpose of this Act. The substance and effect of the appeals filed by the Revenue was to challenge the order passed by the Commissioner of Income-tax (Appeals). The appeals filed by the Revenue were required to be heard on the merits by the Tribunal instead of dismissing the same as not valid. In this ..... X X X X Extracts X X X X X X X X Extracts X X X X
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