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2010 (4) TMI 146

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....the respondent. JUDGMENT 1. These appeals are being disposed of by a common order as they raise similar issues and also arise from the common order passed by the Income-tax Appellate Tribunal on September 30, 2008 in IT(SS)A No. 209/ Del/05 and IT(SS) (A) No. 210/Del/05 in respect of the block period which cover the assessment years 1997-98 and 2003-04 (up to October 23, 2002). In I. T. A. No. 3....

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.... matter in the Tribunal's order that is impugned before us. The learned counsel for the appellant submitted that a specific plea was taken with regard to the jewellery found in the locker. However, the Tribunal has not considered the jurisdictional aspect which was the preliminary issue taken by the appellant. The learned counsel for the appellant also contended that certain evidence such as photo....

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....dence to indicate that these items were acquired during the block period. The learned counsel for the appellant has drawn our attention to the Central Board of Direct Taxes Instruction No. 1916 dated May 11, 1994, which also, according to him, was not considered by the Tribunal in the correct perspective The learned counsel for the Revenue controverted all the submissions made by the learned couns....