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Issues:
1. Assessment years 1986-87 and 1987-88 - Reopening of assessments under section 148. 2. Legality of reassessment orders under section 144 of the IT Act. 3. Non-service of notice under section 148 of the IT Act. 4. Quashing of reassessment orders by the CIT(A). 5. Compliance with directions of the CIT(A) for reframe of assessments. Analysis: 1. The case involved cross-appeals and cross-objections related to the same assessee for the assessment years 1986-87 and 1987-88. The Assessing Officer reopened the assessments under section 148 due to suspicions of black money transactions related to advance licenses under the Duty Exemption Scheme. The Department faced challenges in serving notices to the assessee, leading to ex parte assessments under section 144 of the IT Act. The CIT(A) set aside the assessment orders and directed a fresh assessment after providing the assessee a fair opportunity to be heard. 2. The assessee challenged the legality of the reassessment orders under section 144, arguing that ex parte orders were unjustified as the books of account were already with the Department. The CIT(A) quashed the reassessment orders, emphasizing the importance of proper procedures and the need for fair assessments. The Revenue appealed against this decision, seeking to set aside the assessments and remand the matter to the Assessing Officer for fresh adjudication. 3. The issue of non-service of notice under section 148 was raised by the assessee, highlighting the lack of compliance with procedural requirements. The Assessing Officer failed to issue or serve notices upon the assessee, leading to concerns about the validity of the reassessment proceedings. The CIT(A) considered these arguments and quashed the reassessment orders based on procedural irregularities. 4. The CIT(A) directed the Assessing Officer to reframe the assessments afresh, allowing the assessee an opportunity to file returns and produce necessary documents. The assessee filed cross-objections challenging the validity of assessments due to non-service of notice under section 148. However, the Tribunal found that the Assessing Officer had complied with the CIT(A)'s directions, and the assessments were upheld. 5. Ultimately, the Tribunal dismissed the appeals filed by both the assessee and the Revenue. The cross-objections filed by the assessee were also dismissed, as the Tribunal upheld the orders of the CIT(A) regarding the assessments for the years 1986-87 and 1987-88. The decisions were based on a thorough analysis of the facts, legal procedures, and compliance with the directions issued by the CIT(A).
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