2006 (5) TMI 306
X X X X Extracts X X X X
X X X X Extracts X X X X
....used the record. The relevant facts in this case are that there was search in this case of 20-6-2000 as a result of which assessment for the block period 1-4-90 to 20-6-2000 was made by the Assessing Officer under section 158BC of the Income-tax Act, 1961 vide order dated 25-6-2002 at an income of Rs. 6,77,323. The CIT(Appeals) had directed the Assessing Officer to give relief to the assessee in accordance with Chapters IV, VI & VIA by following the judgment of the Chandigarh Bench of the Tribunal in the case of Satpal Singh v. ACIT 67 TTJ 602 . While giving appeal effect, relief was allowed to the assessee on account of salary and rental income of Rs. 3,55,999. The Assessing Officer allowed relief to the assessee. However, subsequently, no....
X X X X Extracts X X X X
X X X X Extracts X X X X
....he assessee was 'nil'. Reliance was placed on the decision of the Tribunal in the case of Bhag Chand Jain v. ACIT, 65 ITD 11 . It was contended that the decisions referred to in the order of the CIT(A) relate to such cases where tax was deducted at source and are therefore, inapplicable to the facts of this case. 4. In counter reply Learned counsel for the assessee contended that in this case search was conducted on 20-6-2000. Assessment was made on 28-6-2002. The CIT(Appeals) passed the order on 16-1-2003. Said order was confirmed by the ITAT vide order dated 27-6-2005. It was contended that since the order of the Assessing Officer is merged with the order of the CIT(Appeals) and ultimately with the order of the Tribunal, the Assessing Of....