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2024 (7) TMI 1392

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..... ugned revisional order dated 06.02.2024 [Annexure-12 to CRP No.34/2024] whereby the common reassessment order dated 14.05.2019 passed by the Assessing Officer upon remand in a previous revisional order dated 16.08.2016 concerning the financial years 2006-07, 2007-08 and 2008-09 have been set aside and the matter has been remanded to the Assessing Authority for reassessment. 3. Petitioner, being aggrieved, has challenged the common impugned order in these civil revision petitions inter alia on the grounds that: (i) The assessment proceedings for the financial year 2006-07 were barred on grounds of limitation in view of Section 33 of the TVAT Act having been undertaken on 15/18.11.2012 i.e. after five years. (ii) The assessment order an .....

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..... der recorded by the revisional authority in the impugned order dated 06.02.2024. The contention of the petitioner has been duly referred to and on being satisfied thereupon, the impugned reassessment order dated 14.05.2019 concerning the financial years 2006-07, 2007-08 and 2008-09 has been set aside and the matter has been remanded for reassessment to the Superintendent of Taxes, Charge-IV, Agartala. Therefore, the petitioner should not have any grievance to approach this Court for a determination on these legal and factual issues involving the adjudication on merits of the audit objection and also on grounds of violation of principles of natural justice at the reassessment stage. He further submits that the learned Assessing Authority wou .....

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..... -07 is not barred by limitation in terms of Section 33 of the TVAT Act, he would proceed to determine other grounds raised on merits so far as that financial year is concerned. So far as the other financial years are concerned, the Assessing Authority will deal with each of the grounds on law and on merits raised by the petitioner while passing a reassessment order. Since the assessment proceedings has lingered for about twelve years by now, we deem it proper to direct the Assessing Authority to conclude the exercise within a period of three months from the date of receipt of copy of this order. Needless to say the petitioner/assessee shall cooperate in the reassessment exercise without fail. With these observations, all the three instant r .....

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