TMI Blog2001 (1) TMI 54X X X X Extracts X X X X X X X X Extracts X X X X ..... s been referred for the opinion of this court under section 256(2) of the Income-tax Act, 1961 (in short, the "Act"), by the Income-tax Appellate Tribunal, Delhi Bench "A", New Delhi (in short, "the Tribunal") : "Whether, on the facts and in the circumstances of the case, the Income-tax Officer was justified in the course of reassessment proceedings initiated under section 147(a) for including t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of reassessments, it was noticed that in the original assessments tax was levied on the assessees at the rates applicable to their total income even though they were residents but not ordinarily residents and no declaration had been filed in terms of section 113(3) of the Act. Accordingly, tax was levied at the rates applicable under section 113(1) of the Act. Though the assessees did not chall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r. On being moved, directions were given, as aforesaid, for referring a case. We have heard learned counsel for the assessees and learned counsel for the Revenue. The primary stand of the assessees is that reopening having been done on one ground, it was not open to take into account another ground for the purpose of reassessment. Learned counsel for the Revenue, on the other hand, submitted th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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