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2017 (11) TMI 681

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..... s. The assessee had incurred a sum of ₹ 19,99,107/- of prior period expenses but added only ₹ 8,18,923/- out of this sum instead of the entire sum of ₹ 19,99,107/-. The Assessing Officer responded to such audit objection in letter dated 10.02.2011 conveying that he does not agree to such audit objection since according to him the expenditure had actually crystallized during the y .....

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..... - Dated:- 31-7-2017 - MR. AKIL KURESHI AND MR. AKIL KURESHI, JJ. For The Appellant : Mr Km Parikh, Advocate ORAL ORDER ( PER : HONOURABLE MR.JUSTICE AKIL KURESHI) 1. The Revenue is in appeal against the judgement of the Income Tax Appellate Tribunal dated 30.05.2016 raising the following question for our consideration: Whether on the facts and in the circumstances of the .....

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..... the reopening of assessment on the ground that the same was prompted by audit objection. The Tribunal noticed a note placed by the Assessing Officer at the end of the order of reassessment stating that the assessment has been completed in view of the audit objection raised by the Revenue Audit Party. 3. Since the order of the Tribunal was somewhat brief, we had requested the learned counsel for .....

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..... it objection since according to him the expenditure had actually crystallized during the year under consideration and therefore rightly allowed. He concluded that such objection may therefore be dropped. Despite this, he eventually issued the notice for reopening by recording reasons which only referred to this discrepancy. We also have further letter dated 30.12.2011 of the Assessing Officer to t .....

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