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TMI Blog2019 (3) TMI 1312X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the only objection raised by the Department appears to be regarding alleged tax avoidance. We asked Ld. DR to show us any material in support the plea of tax avoidance. However, at this stage he was unable to furnish any such material. We must note that this matter has been adjourned at least on two occasions. Hence it is not possible to adjourn it any further. We must also note that Ld.FCA fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment is on record. In the enclosure to that report, the Department has raised objection in the following manner:- 4.2.8 It is also proved beyond doubt that the entities here come naturally to for man AOP rather than being assessed as separate entities. In Income tax Act there is no provision to assess separate entities particularly when they have made consortium. As per the provision of the I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h notice under section 143(2) was issued on 12.02.2017, it cannot be said that the question raised by the assessee in the application is specifically pending before any income-tax authority. We may quote the relevant part of report dated12.03.2019: On selection of the case of scrutiny, notice u/s 143(2) was issued on 12.07.2017which was duly served through e-mail on same date and was also sen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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