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2007 (4) TMI 186

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..... d to the disallowance of expenses, the entire range of issues couldn’t have been reopened including those issues that were already decided in favour of Assesses & hadn’t been appealed against - no substantial question of law arise - I.T.A. NO 458 OF 2003. - - - Dated:- 27-4-2007 - MADAN B. LOKUR and V.B. GUPTA JJ. JUDGMENT:- 1 The Revenue is aggrieved by an order dated 8 th October, 200 .....

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..... lakhs in respect of a Vedic Science Conference, which appears to have gone on for about 4 to 6 months in which more than 4,000 delegates had participated. 4 The Assesses was aggrieved by the disallowance of this amount and, therefore, filed an appeal. 5 The Commissioner of Income Tax (Appeals) remanded the matter to the file of the Assessing Officer with certain directions. The Assesses pref .....

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..... dy been settled in the original assessment order that was passed way back in 1984 and that issue could not be reopened. The only controversy was with regard to the disallowance of expenses of Rs. 90 lakhs towards hotel expenses, mess expenses and utilization 8 of tents. The Tribunal noted that on facts, the departmental authorities were fully justified in holding that the expenses were in conne .....

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..... as not an issue before the appellate Forum. The Revenue could have taken some other steps to have that finding set aside but the Revenue did not do so. On the basis of the Assessee's appeal with regard to the disallowance of Rs. 90 lakhs, the entire range of issues could not have been reopened including those issues that were already decided in favour of the Assesses and not appeal against the con .....

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