TaxTMI 
TaxTMI 
2013 (4) TMI 423
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....se two appeals are heard together, inasmuch as, the same assail the same judgment of the Tribunal. 2. On 13th July, 2007, the Tribunal passed the order impugned in these appeals. As such, the order of the Tribunal is not interferable, inasmuch as, at the time when the Tribunal had pronounced the judgment, law then applicable was applied. The fact remains that the assessment order, pertaining to t....
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....biguous terms to the above additions. Similar was the case for the Assessment Year 1997-1998. In response to the notice under Section 271(1)(c) of the Act, assessee held out that, in order to buy peace and in order to bring to an end the controversies inter se the department and the assessee, the assessee accepted the additions, but, in fact, there was no suppression by him or overstatement on his....
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.... that non-recording of satisfaction is a jurisdictional error and, accordingly, any step taken without recording such satisfaction is of no effect. The Tribunal has, accordingly, held that the said penalty proceedings, initiated under Section 271(1)(c) of the Act, are non-starter, as the same were initiated without recording satisfaction by the Assessing Officer as regards concealment of particula....
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....initiation of the penalty proceedings under the said clause (c)." 5. In view of the insertion of the said law with retrospective effect from 1st April, 1989, having regard to the fact that the Assessing Officer added income and disallowed expenditure and depreciation and, at the same time, observed as regards initiation of penalty proceedings under Clause (c) of Sub-Section (1); the said assessme....