2015 (5) TMI 121

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....ar Garg & Shri Mukul Mathur, Advs. ORDER 1. The grievance of the appellant is that the notice of the CIT dated 03/04.09.2009 seeking to revise the merits of the completed assessment for AY 2006-07 has been upheld by the ITAT and the matter remitted after upholding the initiation of revision proceedings. 2. The facts are that the appellant's return for AY 2006-07 was finalized by an order da....

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....s on the objections raised by the assessee as stated in the following terms: "7.................But the action of the Ld. CIT in not considering the merits of objections raised by assessee vide reply dated 11.1.2010 placed at pages 3 to 12 of paper book and just remitting back to Assessing Officer for re-adjudication was not appropriate." 3. Learned senior counsel for the assessee argues that th....

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....as submitted that given the fact that the CIT did not record any findings on the merits of the objections as to the initiation of proceedings itself on both the aspects, i.e. erroneous view of the AO and the potential consequence to the revenue, the ITAT's affirmation of such assumption of jurisdiction is untenable and the remand for the limited purpose of deciding objections is merely academi....