TMI Blog2022 (2) TMI 120X X X X Extracts X X X X X X X X Extracts X X X X ..... ] It was therefore set aside and the case was remitted back to pass a speaking order. The respondent has now passed the impugned order/communication over ruling the objection of the petitioner. By the impugned order, the respondent has merely concluded the reasons why the assessment has been reopened. The fact that the assessment has been reopened itself does not mean that the re-assessment has been completed. It is open for the petitioner to participate in the proceedings and make appropriate submissions before the respondent by convincing the respondent to the effect that there is no case made out for revising the assessment completed earlier. - W.P.No.28305 of 2021 And W.M.P.Nos.29890 & 29892 of 2021 - - - Dated:- 4-1-2022 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r an Assessment Order came to be passed for reopening the assessment on 22.11.2006 wherein, the respondent had disallowed the expenses incurred by the petitioner towards web casting charges for a sum of ₹ 4,00,00,000/- and restricted the expenditure only for a sum of ₹ 4,48,04,840/-. 6. The learned counsel for the petitioner further submits that further an appeal has been filed before the Appellate Commissioner, the disallowance of expenditure towards web casting charges for the balance sum of ₹ 2,00,00,000/- was allowed by CIT (Appeals) by an order dated 11.01.2008 in ITA No.655/2006-2007 pursuant to which, a revised assessment was issued by the respondent on 12.09.2008 after giving effect to the aforesaid order. The r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ravention of the directions of the Hon'ble Supreme Court inasmuch as no speaking order was passed in terms of the decision of the Hon'ble Supreme Court in G.K.N.Driveshafts case (referred to supra). It was therefore set aside and the case was remitted back to pass a speaking order. 13. The respondent has now passed the impugned order/communication over ruling the objection of the petitioner. By the impugned order, the respondent has merely concluded the reasons why the assessment has been reopened. The fact that the assessment has been reopened itself does not mean that the re-assessment has been completed. 14. It is open for the petitioner to participate in the proceedings and make appropriate submissions before the respond ..... X X X X Extracts X X X X X X X X Extracts X X X X
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