TMI Blog2001 (3) TMI 244X X X X Extracts X X X X X X X X Extracts X X X X ..... (A), Jalandhar, in respect of asst. yrs. 1981-82 to 1985-86 for which there were two assessment orders of the ITO, A-Ward, Moga-one in respect of asst. yr. 1981-82 and a common order in respect of four years with which we are dealing in this order. 2. As far as the asst. yrs. 1982-83, 1983-84 and 1984-85 are concerned, the original assessments were framed as under: ---------------------------- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date further said year in ITA 293 (Asr) 1991 as the basis and for the same reasons, we cancel the three years' order. The reassessment for the year 1985-86 is cancelled on the ground that transactions with M/s Ram Kumar Parshotam Dass on the facts of the case could not be said to be bogus. For this also, we make our order of even date in the assessee's own case in respect of asst. yr. 1981-82 (rel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1993 ORDER UNDER S. 255(4) OF THE IT ACT, 1961 There being difference of opinion between us, who have heard the appeals, the following point of difference is framed for reference to the Hon'ble President of the Tribunal under s. 255(4) of the Appellate Tribunal under s. 255(4) of the IT Act, 1961: "Whether, on the facts and in the circumstances of the case, the view taken by the J.M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : 30th March, 2001 The following point of difference of opinion was referred to me for decision under s. 255(4) of the IT Act, 1961: "Whether, on the facts and in the circumstances of the case, the view taken by the J.M. that in view of his proposed order in ITA No. 293/Asr/1991 in respect of asst. yr. 1981-82 the reassessments for the asst. yrs. 1982-83, 1983-84 and 1984-85 could not be sus ..... X X X X Extracts X X X X X X X X Extracts X X X X
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