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1982 (2) TMI 30

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..... consequent upon a seizure of Rs. 84,000 by the Enforcement Directorate during a raid conducted at his premises. The amount seized was claimed by the petitioner as his. As a result of this claim, an alternative or protective assessment was made upon the petitioner, Abdul Kareem Hajee, in respect of the amounts seized. The respective orders of assessment relating to Hamsa and the petitioner are exs .....

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..... or the assessment year 1970-71,on Rs. 60,278 works out to Rs. 24,682. This is charged. This should be paid as per demand notice. " Exhibit P-6 was affirmed in revision by the Commissioner by ex. P-7 dated March 4, 1978. It is contended by the petitioner's counsel, Shri Paripoornan, that in so far as ex. P-2A was set aside by the AAC by ex. P-3A, no interest had become payable by the petitioner o .....

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..... n before the appellate authority. The order of the appellate authority itself was likewise provisional during the period allowed for filing an appeal or during the pendency of the appeal. When the order of the AAC concerning the petitioner was finally set aside by the Tribunal, thereby affirming ex. P-2A order of the ITO, the cloud hanging over ex. P-2A was removed and its finality was affirmed. C .....

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