TMI Blog2023 (9) TMI 961X X X X Extracts X X X X X X X X Extracts X X X X ..... 's case that he has moved from Quetta in West Pakistan. While moving to India, he brought with him cash amounting to approximately Rs.27,50,000/-, and jewellery weighing 150 grams. So far as the cash is concerned, Rs. 27,50,000 was deposited by the petitioner in Bank of India, Khanpur Branch, Delhi - as guided petitioner could take recourse to a statutory appellate remedy. HELD THAT:- It ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rity. The expression annul is wider in scope than the power to set aside. We have queried Mr Khan as to how the petitioner got Indian currency into the country, and deposited the same in the aforementioned bank. As assessee says that he will obtain instructions in that regard. List the matter on 11.09.2023. - Hon'ble Mr. Justice Rajiv Shakdher And Hon'ble Mr. Justice Girish Ka ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment order has been passed under Section 147, read with Section 144 of the Act. 4. This assessment order concerns Assessment Year (AY) 2016-17. 5. The AO appears to have formed the view that income amounting to Rs.30,85,500/-, which is otherwise chargeable to tax, has escaped assessment. 6. It is the petitioner‟s case that he has moved from Quetta in West Pakistan. While moving t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... medy. 8.1 Mr Khan says that under Section 251 of the Act, the appellate authority will not be able to set aside the impugned assessment order dated 31.05.2023. 9. According to us, prima facie, this is a misreading of the provision. 10. The provision, inter alia, confers power of annulment on the appellate authority. The expression annul is wider in scope than the power to set aside. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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