2014 (5) TMI 667

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....ssai, learned Advocate for the Appellant. 2. This Appeal is filed by the Revenue challenging the Order passed by the Income Tax Appellate Tribunal in Appeal No. 79/PNJ/2012 and CO No. 11/PNJ/2012 (A.Y. 2005-06) on 14.06.2013 allowing the cross objections filed by the Assessee and holding that the Appeal filed by the Revenue vide I.T.A.T. No. 79/PNJ/2012 is rendered infructuous. The questions of l....

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....ars from the end of the relevant assessment year and the AO is free to issue notice within four years and there is no concept of change of opinion as per the amended provision of the Act. 3. We have heard the learned Advocate for the Appellant and have examined the record with her assistance. We find that the Tribunal has properly appreciated the facts on the record and has given its findings whi....