9911796707
TMI Blog2022 (3) TMI 535X X X X Extracts X X X X X X X X Extracts X X X X ..... nt was determined and it is admitted position that till date petitioner has not paid a single penny in respect of the aforesaid demand - second round of litigation initiated by the petitioners before this Court - HELD THAT:- It is a well-settled principle of law that power of Appellate Authority is much wider than the Revisional Authority and the Commissioner in exercise of his discretionary power ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Constitution of India tactfully indirectly to get interference in assessment order which the Commissioner in exercising the power under Section 264 of the Act has refused and this Court has also refused in the first round of litigation. - WPA 2852 of 2022 - - - Dated:- 2-3-2022 - MD. NIZAMUDDIN, J. Mr. Abhrotosh Majumdar, Ld. Sr. Adv., Mr. Himangshu Kumar Ray For the Petitioners. M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion, writ petition, being WPA 11041 of 2021 was dismissed by this court by an elaborate order dated 25th August, 2021 and since the aforesaid writ petition was dismissed without going into the merits of the impugned assessment order dated 4th June, 2021, was an appealable order before the Commissioner of Income Tax(Appeal) which has a very wide power to go into both on facts and on question of la ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t order in question which is not Appealable though at the time of filing the revisional application there was no bar of limitation to file the appeal. It is a well-settled principle of law that power of Appellate Authority is much wider than the Revisional Authority and the Commissioner in exercise of his discretionary power of revision under Section 264 of the Act cannot act as an Appellate Au ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ew to make out a case to come up before this Court again under Article 226 of the Constitution of India tactfully indirectly to get interference in assessment order which the Commissioner in exercising the power under Section 264 of the Act has refused and this Court has also refused in the first round of litigation in WPA No. 11041 of 2021. Considering the facts and circumstances of the case a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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