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TMI Blog2008 (10) TMI 565X X X X Extracts X X X X X X X X Extracts X X X X ..... Act which has been introduced with effect from 1-4-2008. However, we feel that no reliance on that provision can be placed for two reasons. The first reason being that the said provision is not applicable to the assessment year 2001-02. The second reason being that this argument was not at all being raised before the Tribunal. – Decided against the revenue. - IT APPEAL NO. 1203 OF 2008 - - - Dat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... asmuch as according to the assessee no notice under section 148 had been issued/served upon the assessee and, therefore, all subsequent proceedings including the framing of the reassessment order, according to the assessee, were liable to be set aside. The Tribunal permitted the assessee to take the additional plea before it inasmuch as it was a jurisdictional plea which went to the root of the ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... el for the appellant sought to place reliance on the provisions of section 292BB of the said Act which has been introduced with effect from 1-4-2008. However, we feel that no reliance on that provision can be placed for two reasons. The first reason being that the said provision is not applicable to the assessment year 2001-02. The second reason being that this argument was not at all being raised ..... X X X X Extracts X X X X X X X X Extracts X X X X
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