1991 (4) TMI 40

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....ing to the assessee's assessment for the assessment year 1970-71, the Income-tax Appellate Tribunal has referred to this court the following two questions of law for opinion under section 256(1) of the Income-tax Act, 1961 : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in cancelling (sic), the order of the Appellate Assistant Commissioner setting asid....

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....ssessee before the Appellate Assistant Commissioner that it was denied reasonable opportunity with regard to the alleged undeclared consideration and compensation received for the reasons given in the order. The Appellate Assistant Commissioner set aside the assessment and directed the Income-tax Officer to give the assessee a fresh opportunity to explain its position as demanded in the assessee's....