2012 (6) TMI 538

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..... ssment order which was again challenged by the assessee before the Appellate Commissioner who set aside the order on merits but did not go into the question of correctness of the re-opening of the assessment under Section 147 of the Act – Held that:- As the reassessment order has been set aside on merits and it has attained finality, the appellant cannot be said to be an aggrieved person who is en .....

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..... passed the reassessment order. Aggrieved by the same, the assessee preferred an appeal. The appellate Commissioner set aside the said order and remanded the matter back to the assessing authority. Again after such remand, the assessing authority passed the assessment order which was again challenged by the assessee before the Appellate Commissioner who set aside the order on merits but did not go .....

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..... urisdiction also which is not found favour with the authorities. It is in respect of the said portion of the order, the present appeal is filed. As the reassessment order has been set aside on merits and it has attained finality, the appellant cannot be said to be an aggrieved person who is entitled to prefer an appeal merely on the ground that the ground of jurisdiction has been held against the .....

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