TMI Blog1981 (12) TMI 99X X X X Extracts X X X X X X X X Extracts X X X X ..... Bhandarkar, Madras for the asst.yr.1974-75. "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the reassessment made u/s 147(b) for the asst.yr.1974-75 was without jurisdiction and invalid in law?" 2. The assessee sold a property under construction and had included interest on borrowed capital as part of the cost of construction purpor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tenable argument as there is even a High Court decision in favour of the assessee s computation in the original assessment Audit view to the contrary cannot therefore be treated as anything more than a legal opinion . The Tribunal has merely followed the law as settled by the Supreme Court in holding that there is no jurisdiction. Hence there is no referable question of law and the reference appl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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