2014 (5) TMI 627

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.... 1. This is an appeal filed by the revenue. It challenges the order passed by the Income Tax Appellate Tribunal dated 20th May, 2011. The substantial question of law is stated to be the one framed at paragraph 5 of the memo of appeal. 2. Upon query from the Court, the learned counsel Mr. Singh submits that, if the manner in which this question is framed is not appealing to the Court, then, time....

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....s in the context of the undisputed facts. The assessee is a Company engaged in the business of manufacturing and selling of steam boiler. It filed the return of income for the assessment year 19971998 on 29th January, 1998 declaring a total income of Rs.24,86,06,650/. The Assessing Officer passed an order under Section 143(3) of the Income Tax Act, 1961, dated 30th March, 2000. The assessment was ....

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.... would not justify passing of the impugned order dated 31st March, 2003, is the conclusion reached concurrently in this case. It is in that context that the Income Tax Appellate Tribunal and the Commissioner of Income Tax (Appeals) observed that the Assessing Officer failed to reach the requisite satisfaction. His belief should be in accordance with statutory provision and must meet requirement th....