2005 (8) TMI 734

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..... M. Both the appeals filed by the assessee are directed against two separate orders of the learned CIT(A). The appeals relate to the asst. yrs. 1994-95 and 1995-96. 2. In both the appeals, ground No. 1 taken by the assessee reads as under: "1. Reassessment-Invalid 1.1 The learned CIT(A) failed to appreciate that the learned AO erred on facts and in the circumstances of the case and in .....

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..... for issuing notice under s. 147/148 were not supplied to the assessee despite requests by him to the Departmental authorities) In this connection, he invited our attention to the order of the learned CIT(A) and submitted that even the leaned CIT(A) had not given a copy of the reasons recorded for initiating the proceedings under s.. 147/148 with the result that the assessee was deprived of the opp .....

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..... f the learned CIT(A) does not show that a copy of the remand report was supplied to the assessee. Perusal of the orders passed by the Departmental authorities also do not show that the reasons required to be recorded by law for initiating proceedings under s. 147/148 were supplied to the assessee. We, therefore, consider it appropriate to set aside the order of the learned CIT(A) and restore the m .....

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