9911796707
TMI Blog2020 (3) TMI 1378X X X X Extracts X X X X X X X X Extracts X X X X ..... here these additions were made in a substantive manner - According to the tribunal, since this substantive addition had been set aside and remanded, the case of the assessee required a re-look - HELD THAT:- We find from the impugned order of the tribunal that it has not confined itself to this narrow issue but has made consideration of issues which were not remanded to it. We find also from the im ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecting the assessing officer to examine the facts of the case once more after hearing the assessee, taking into account "further developments in the block assessment" and make a fresh assessment order. ₹ 1186 lakhs were added to the account to the assessee on a "protective basis". This protective addition was made in connection with a block assessment order made in the case of Shaw Wallace ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (SS)A No. 54/Cal/98 dated 8.10.99. As such, new addition of ₹ 12,41,80,000/- (mentioned in course of hearing as ₹ 12,41,00,000/- in reassessment is bad in law and not permissible as per law, need to be detected. (ii) That the A.O. was wrong in changing the findings given by his predecessor in the original assessment. No fresh material or evidence, as such change in opinion and findin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces of deposit in two Bank A/cs. Stands well explained. As such, addition need to be deleted. We find also from the impugned order of the tribunal dated 31st March, 2005 that the tribunal has not addressed these issues in the manner that they should have been dealt with in accordance with the earlier order of the tribunal dated 8th October, 1999. For those reasons, we set aside the impugned ord ..... X X X X Extracts X X X X X X X X Extracts X X X X
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