9911796707
TMI Blog2007 (7) TMI 178X X X X Extracts X X X X X X X X Extracts X X X X ..... filed further appeals before the Income-tax Appellate Tribunal - Tribunal on that sole ground itself, could have rejected the appeals - HC decline to answer the questions of law raised for consideration - I.T.A. NOS 18,25 AND 26 OF 2007 - - - Dated:- 18-7-2007 - H.L. DATTU C.J. AND K.T. SANKRAN J. JUDGMENT The judgment of the court was delivered by H. L. DATTU C. J .—Since the issues ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessing authority in the sense, that, he was really not questioning the correctness or otherwise the orders of reassessment passed by the assessing authority for the assessment years 1993-94, 1994-95 and 1996-97. The first appellate authority has noticed the submissions made by the learned representative of the years. In the orders by the first appellate authority, there is a statement by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sult, the appeal for the assessment years 1991-92, 1992-93 and 1995-96 are partly allowed and for the assessment years 1993-94, 1994-95 and 1996-97 are treated as dismissed." 5 Having not objected to the orders passed by the assessing authority in respect of the assessment years 1993-94, 1994-95 and 1996-97 and having allowed the first appellate authority to pass an order in a particular manne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ought not to have held that the reopening under section 147 is bad in law more so in view of the judgment of the Supreme Court ?" 8 Shri Anil D. Nair, learned counsel for the assesses would submit on the merits of the appeal. Per contra, Shri George K. George, learned standing counsel for the Revenue would submit that the first and foremost, having conceded before the first appellate authority ..... X X X X Extracts X X X X X X X X Extracts X X X X
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