1998 (12) TMI 64

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... red the following question of law to this court for opinion at the instance of the assessee : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the Income-tax Officer could make additions in respect of sources of income which were not considered by him in the original assessment proceedings ?" The relevant assessment years are .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... r, make any other enquiries that he deems fit for completing the assessment. The assessments for all the three years are set aside to be made de novo and for statistical purpose the appeals are allowed." He, therefore, submits that the entire assessment having been set aside, it was open to the 'Income-tax Officer to make a fresh assessment in accordance with law after making due enquiries, whi .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... as the same powers in making the fresh assessments as he had originally when making an assessment under section 143(3) of the Act. The scope and ambit of the enquiry for assessment is in no way restricted in such a case. In the instant case, the entire assessments had been set aside by the first appellate authority with a direction to make fresh assessments de novo after making necessary enquir .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X