Circular u/s 119 is binding; non-compliance leads to erroneous assessment, harming Revenue's interest. Commissioner's decision upheld.

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Full Text of the Document

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....When circular is issued under Section 119 of the Act and its validity is upheld it is binding on the Assessing Officer. Not taking recourse thereto and passing the order amounted to making assessment without conducting proper inquiry and investigation as enjoyed by law which was also warranted in the facts of this case and, therefore, the Commissioner was right in holding that such assessment was erroneous and prejudicial to the interest of the Revenue. .... - HC....