2018 (2) TMI 1992

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..... nature of breach evidencing non-application of mind? - Revenue objects to question no.(ii) being admitted, as he states that this issue was not urged before the Tribunal - HELD THAT:- We are of the view that this is an issue of jurisdiction. Therefore, it could be raised before us as it goes to the root of the dispute. Issue of jurisdiction can be urged at any time i.e. even before the appeal Cou .....

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..... f the Act with reference to addition of gift which were clearly disclosed in the original return of income? (ii) Whether on the facts and circumstances of the case, the entire proceedings for penalty under Section 271(1)(c) of the Act are rendered without jurisdiction as it has been commenced,confirmed and upheld on composite ground of concealment of income / furnishing of inaccurate particul .....

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