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2018 (12) TMI 1797

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..... ions of law arise for consideration in this appeal. The Commissioner has sent back the matter for determination by the Assessing Officer. However, certain observations of fact has been made. Therefore, we are of the view that when the matter is sent back for re-determination for the Assessing Officer, the issues are to be kept open. Hence, we are of the view that the Assessing Officer shall accept .....

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..... of the assessee. Thereafter, proceedings were issued under Section 263 of the Act by the Principal Commissioner of Income Tax, Bengaluru. The Principal Commissioner of Income Tax was of the view that the order of the Assessing Officer was erroneous and prejudicial to the interests of the Revenue. The assessment order was set-aside with a direction to reframe the assessment in accordance with law, .....

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..... no query was raised by the Assessing Officer regarding purchase and sale of immovable property during the assessment proceedings is correct? iii. Whether on the facts, in the circumstances and on the grounds and contentions urged, the Tribunal was right in holding that Section 50C of the Income Tax Act, 1961 was applicable to the instant case? iv. Once the Revenue has accepted an a .....

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..... ame is disputed by Sri Jeevan J. Neeralgi, the learned counsel for the respondents. 5. On hearing learned counsels, we are of the view that no substantial questions of law arise for consideration in this appeal. The Commissioner has sent back the matter for determination by the Assessing Officer. However, certain observations of fact has been made. Therefore, we are of the view that when the ma .....

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