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of <h1>Consolidated Appeals under Section 263 Upheld for Low-Income Companies</h1> <h3>Techno Tracom (P) Ltd. Versus I.T.O., Ward-8 (3), Kolkata AND Agave Tradecom Pvt. Ltd. (Now converted as Agave Tradecom LLP) Versus Principal Commissioner of Income Tax, Kolkata-I</h3> Techno Tracom (P) Ltd. Versus I.T.O., Ward-8 (3), Kolkata AND Agave Tradecom Pvt. Ltd. (Now converted as Agave Tradecom LLP) Versus Principal Commissioner ... Issues Involved:Appeals challenging orders passed by CIT u/s 263 of the Income-tax Act, 1961 based on similar facts and common grounds.Analysis:1. The assessees challenged separate orders passed by the CIT u/s 263 of the Income-tax Act, 1961. The Tribunal decided to consolidate the appeals due to similar facts and grounds.2. The assessees repeatedly sought adjournments for their appeals, but on the latest hearing date, no one appeared. The issues raised were deemed covered against the assessees by previous tribunal orders.3. The cases involved companies with low income filing returns, receiving notices u/s 148 for income escapement, and facing assessments with nominal additions. CITs passed orders u/s 263, leading to appeals before the Tribunal.4. The Tribunal disposed of numerous cases with similar issues, referring to a key order involving Subhlakshmi Vanijya Pvt. Ltd. for A.Y. 2009-10.5. The Tribunal reiterated conclusions from a previous order, including the CIT's power to revise assessments due to inadequate inquiries by AOs, proper service of notices u/s 263, and the jurisdiction of the CIT over the AO who passed the order.6. Various conclusions were drawn, such as the validity of orders passed after amalgamation, the timing of limitation periods, and the impact of search proceedings on CIT's revision powers.7. Based on the previous order's view, the Tribunal upheld all impugned orders, leading to the dismissal of all appeals.This detailed analysis outlines the Tribunal's decision on the appeals challenging CIT's orders under section 263 of the Income-tax Act, emphasizing the consistency of facts and grounds across the cases and the application of previous conclusions to uphold the impugned orders.
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