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TMI Blog2023 (2) TMI 1331X X X X Extracts X X X X X X X X Extracts X X X X ..... hik Ramana Puttam Reddy, learned counsel for the assessees/appellants and Ms. K.Mamata Choudary, learned Standing Counsel, Income Tax Department and Ms. Sapna Reddy, learned counsel representing Mr. J.V.Prasad, learned Standing Counsel, Income Tax Department for the respondents. 3. All the related appeals have been filed under Section 260A of the Income Tax Act, 1961 (briefly referred to hereinafter as 'the Act') assailing the common order dated 21.03.2022 passed by the Income Tax Appellate Tribunal, Hyderabad Bench 'A', Hyderabad (briefly referred to hereinafter as 'Tribunal') disposing of the following appeals corresponding to the relevant assessment years: Sl.No. & Appellant ITA No. Asst. Year 1. Dakshin Infrastructures Private L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 20 2017-18 4. Learned Senior Counsel for the appellant has proposed the following questions as substantial questions of law: 1. Whether on the facts and in the circumstances of the case, the Tribunal is correct in upholding the jurisdiction of the assessing officer in initiating reassessment under Section 147 of the Act overlooking the contention of the appellant that the first proviso to Section 147 of the Act is not applicable since there is full and true disclosure of all material facts necessary for assessment? 2. Whether the Tribunal misdirected itself in dealing with a contention based on Section 153-A read with Section 153- C of the Act as if the reassessment is challenged based on the material recovered at the time of search o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal was disallowance of interest expenditure under Section 36(1)(iii) of the Act made by the assessing officer and partly affirmed by the first appellate authority. As a matter of fact, first appellate authority had granted limited relief to the assessees. For the balance relief, appeals were filed by the assessees before the Tribunal. 7. In another batch of appeals, we find that the ground urged before the Tribunal was validity of reopening of assessment proceedings under Section 147 of the Act. 8. However, we find from the order dated 21.03.2022 that instead of adjudicating on the grounds raised by the assessees before the Tribunal, Tribunal had remanded the appeals to the file of the assessing officer. In paragraph 46 of the common ..... X X X X Extracts X X X X X X X X Extracts X X X X
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