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TMI Blog2019 (7) TMI 1056X X X X Extracts X X X X X X X X Extracts X X X X ..... MR A. C. RAO, JJ. For The Appellant (s) : MR VARUN PATEL For The Opponent (s) : MR DARSHAN R. PATEL COMMON ORAL JUDGMENT (PER : HONOURABLE MR.JUSTICE J.B.PARDIWALA) 1. The issue involved in the present group of Tax Appeals for the Assessment Years 1998-99 to 2002-03 is with regard to the additions made by the Assessing Officer in respect of the partially disclosed bank accounts in connectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... i.e. Current Account No.3090 with the Natpur Co-operative Bank Ltd. and the Assessing Officer had made disallowance of Rs. 2,50,000=00 with respect to the said one partially disclosed account (assessment order dated 23.03.2006 - Tax Appeal No.47 of 2018). However, in the remaining Assessment Years, i.e. Assessment Years 1999-2000 to 2002-03, as it was found that the assessee was maintaining two ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sing Officer had adopted non-uniform rate while making the addition with respect to the partially disclosed accounts in connection with the non-operative finance. 6. Mr.Varun Patel submitted that in order to verify the factual aspects, the matters may be remanded back to the Tribunal for deciding the aforesaid issue regarding the uniformity of the estimation rate for additions regarding the part ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appeals. The department may, therefore, be given liberty to request the Tribunal to hear both the sets of appeals together, i.e. the appeals filed by the assessee and the appeals filed by the department against the order of the CIT(A) regarding the issues of non-operative finances. 8. We have heard Mr.Varun Patel, the learned counsel appearing for the Revenue and Mr.Darshan Patel, the learn ..... X X X X Extracts X X X X X X X X Extracts X X X X
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