TMI Blog2016 (2) TMI 1270X X X X Extracts X X X X X X X X Extracts X X X X ..... e, answering the substantial questions of law does not arise for consideration. The Appellate Authority has taken into consideration all these aspects of the matter and recorded a clear finding of fact by assigning valid and cogent reasons, holding that no acknowledgment as such has been produced by the revenue, inspite of affording sufficient opportunity. Therefore, the reasoning given by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Whether on the facts and in the circumstances of the case, the order of the Tribunal in holding that the order of the first appellate authority does not suffer from any legal infirmity is correct without appreciating that the CIT(A) has mentioned in his order that the assessing authority had not issued a notice under section 143(2) on the revised return furnished without appreciating that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ating that the additional ground raised by the assessee was not only misleading but amounted to mis-representation of facts? 2. It is the case of the revenue that the Assessing Officer by his order dated 29.12.2011 considered the revised return of income on 31.3.2011. Being not satisfied with the same, the respondent-assessee filed an appeal before the Appellate Commissioner and the Appellat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has issued notice to the respondent-assessee, but they did not have acknowledgment for having served the same on the assessee. Therefore, he submitted that in view of non- availability of acknowledgment for having served the notice to the respondent-assessee in the records, the substantial questions of law raised in the instant appeal are not sustainable for consideration. Therefore he submitted ..... X X X X Extracts X X X X X X X X Extracts X X X X
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