TMI Blog2019 (12) TMI 987X X X X Extracts X X X X X X X X Extracts X X X X ..... - - - Dated:- 12-11-2019 - Mr. Justice M. Sathyanarayanan And Mr. Justice N. Seshasayee For the Appellant : Mr.T.R.Senthil Kumar JUDGMENT M. SATHYANARAYANAN, J. The Revenue is the appellant. 2. The Joint Commissioner of Income Tax, Special Range-I, Coimbatore, vide Assessment Order dated 06.03.2000. issued ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The Revenue, aggrieved by the order of the the Commissioner of Income-Tax (Appeals)-I, Coimbatore, dated 23.07.2002, filed an appeal before the Income Tax Appellate Tribunal, Chennai, 'D' Bench. The Appellate Tribunal, on assessing the material facts placed before the Assessing Officer at the time of original assessment, has found that the issuance of re-assessment notice under Section 147 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act is barred by limitation? 2. Whether on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in holding that, reassessment under Section 147 was on account of mere change of opinion. 3. Whether on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in allowing the deduc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considered the submissions made by the learned Standing Counsel appearing for the Revenue-appellant 6. In the light of the said circular, the Tax Case Appeal is dismissed on account of low tax effect, however this decision pertains to the Assessment Year 1992-1993 alone, and will not bind any similar substantial questions of law, which may arise in respect of subsequent Assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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