9911796707
TMI Blog1986 (3) TMI 115X X X X Extracts X X X X X X X X Extracts X X X X ..... by this common order for the sake of convenience. 2. The assessee is an AOP deriving income from securities and dividends. The assessment years involved in these two appeals are 1980-81 and 1981-82. 3. The only common ground taken in these two appeals states that the Commissioner (Appeals) should not have dismissed the appeals filed before him by the assessee on the ground that the assessments ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r (Appeals). 5. We have considered the contentions of both the parties as well as the facts on record. It is now well settled that there is no inherent right of appeal and such a right has to be specifically conferred by the express terms of the statute. The assessment orders have been passed under section 143(3) of the Act and so section 246(1)(c) is the relevant section to determine as to what ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessments are made on the basis of the returns filed by the assessee on the incomes declared therein as a protective measure. The remark of the ITO merely means that the ITO reserved the right to proceed against somebody else if permitted under the law. Such a remark cannot give rise to any grievance on the part of the assessee who has been assessed exactly on the basis of the returns filed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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