TMI Blog2019 (9) TMI 1719X X X X Extracts X X X X X X X X Extracts X X X X ..... 8 times higher - HELD THAT: - The perusal of the assessment order would show that the detailed discussion has been made and it is out come after the seizure was made and the various documents were seized. The petitioner contended that the assessment has been made high pitched which is 78 times more. The Assessment Officer justifies the same in the order, which is of course subject matter of adjud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment and as against the amount of Rs. 1,12,31,353/- the assessment was calculated to 87,36,07,803/-, which is 78 times higher. It is further contended that according to the circular which is existing of CBDT, in the case like this, the assessee has to pay 20% of the assessed amount and even application of such circular, if the assessment itself is high pitched then very object of the payment of 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urther contended that the circular of the department itself though prescribes that the appeal of the like nature to be decided within a period of six months, but in the case in hand the respondents may be directed to decide the appeal within a period of one month so that actual high pitched assessment may be decided that whether it is correct or not? eventually the liability of payment of tax. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the petitioner in this case without payment of single amount wanted the appeal to be decided within a short period of time, which cannot be allowed. The perusal of the assessment order would show that the detailed discussion has been made and it is out come after the seizure was made and the various documents were seized. The petitioner contended that the assessment has been made high pit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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