1982 (6) TMI 105

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..... uction to the assessee under section 358 in respect of items like salary paid to export staff, consultation fee and expenses on foreign delegates, is disputed and in second ground the dispute is in respect of deduction of Rs. 53,016 not allowed by the ITO but allowed by the CIT(Appeals) is disputed. 2. When this appeal came for hearing, the Id counsel for the assessee at the very outset submitt .....

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..... ted that section 250 and section 263 under the IT Act, operate in different fields and are independent of each other. 4. Before going through the merits of the issues raised by the revenue in its appeal, we are of the view that the appeal under consideration really does not have any base because the assessment order originally framed by the ITO and to that extent he considered the order of the .....

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..... e in support of it contention/contentions which may be raised by it in the course of such proceedings." As per the above directions the ITO reframed the assessment on 26-3-1980 and mentioned in the very first para of the said assessment order as under : "Original assessment in this case was framed on an income of Rs. 2,47,170 on 20-2-1978 under section 143(3) by ITO Coy Circle Patiala. Later .....

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