TMI Blog2019 (3) TMI 1467X X X X Extracts X X X X X X X X Extracts X X X X ..... e carried out. This Court in the case of UTI Mutual Fund Vs. ITO [2012 (3) TMI 333 - BOMBAY HIGH COURT] had observed that, “If the Assessing Officer has taken a view contrary to what has been held in the preceding previous years without there being a material change in facts or law, that is a relevant consideration in deciding the application for stay. In the present case, prima facie, the Rev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cquire Non-Performing Assets ( NPAs for short) by banks and recover dues from the defaulters. For the assessment year 2016-17, the Assessing Officer passed an order of assessment on 24.12.2018 making certain disallowances and additions in the hands of the assessee which has given rise to a tax demand of ₹ 6.69 crores (rounded off). Against such order of assessment, the petitioner has filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in hands of other similar trusts created under ARCIL. Such order of assessment was challenged before the CIT(A) and by his order dated 3.1.2018, the appeal of the assessee was allowed and all the additions made by the Assessing Officer were deleted. When this fact was brought to the notice of the Commissioner while requesting for stay, the Commissioner in the impugned order, observed that such ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or law, that is a relevant consideration in deciding the application for stay. . 5. In the present case, prima facie, the Revenue is unable to point out any material change in the facts or law on the basis of which the Assessing Officer has made the additions. 6. Under the circumstances, while allowing the Revenue to file reply and adjourning this group of petitions to 22nd March, 2019, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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