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TMI Blog2015 (10) TMI 2378X X X X Extracts X X X X X X X X Extracts X X X X ..... ity of the assessment orders were never argued before the Court nor the amendment application was pressed. There is no error apparent on the face of the record which requires reconsideration or rectification. Since the amendment application was not pressed, it was not open for the Court to consider the validity of the assessment orders so passed during the pendency of the writ petition. - CIVIL MISC. REVIEW APPLICATION No.172677 of 2015, WRIT TAX No. - 451 of 2012 - - - Dated:- 26-10-2015 - Hon'ble Tarun Agarwala And Hon'ble Vinod Kumar Misra, JJ. ORDER 1. We have heard Sri S.P.Gupta, the learned senior counsel along with Sri Rakesh Ranjan Agarwal, senior counsel assisted by Sri Suyash Agarwal for the petitioners on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ication should be allowed. In this regard, the learned counsel contended that a mistake apparent on the face of the record has occurred, which is liable to be rectified. It was urged that amendment application No.195366 of 2014 was filed praying for the quashing of the block assessment order dated 21.3.2014, which was not considered and consequently the review application should be allowed and the matter should be heard denovo. 5. On the asking by the Court, the learned senior counsel fairly conceded that the amendment application was not pressed nor the validity of the assessment order was argued on merits, but, what the learned senior counsel has contended that in view of the finding given by the Court on the validity of the search and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the petitioners and Sri Bharat Ji Agrawal, learned Senior Advocate assisted by Sri Ashok Kumar, learned counsel for the respondents. Put up tomorrow i.e. 17.07.2014 at 10:00 O'clock for hearing. Order Date :- 16.7.2014 (Dr. Satish Chandra,J.) (Tarun Agarwala,J.) Hon'ble Tarun Agarwala,J. Hon'ble Dr. Satish Chandra,J. We have heard Shri Bharat Ji Agrawal, learned Senior Advocate, in response to the argument submitted by Shri S.P. Gupta, learned Senior Counsel for the petitioner. Put up tomorrow i.e. on 18.07.2014 for hearing in rejoinder at 10 O'clock. Order Date :- 17.7.2014 Anurag/- (Dr. Satish Chandra, J) (Tarun Agarwala, J) Hon'ble Tarun Agarwa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efore the first appellate authority against the assessment order. According to the respondents, an appeal had already been filed before the first appellate authority. Whatever may be the reason, the fact remains that the validity and legality of the assessment orders were never argued before the Court nor the amendment application was pressed. 10. In the light of the aforesaid, we are of the opinion, that there is no error apparent on the face of the record which requires reconsideration or rectification. Since the amendment application was not pressed, it was not open for the Court to consider the validity of the assessment orders so passed during the pendency of the writ petition. 11. In view of the aforesaid, we do not find any mer ..... X X X X Extracts X X X X X X X X Extracts X X X X
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