2015 (5) TMI 393

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.... HONOURABLE MR.JUSTICE M.R. SHAH) [1.0] Feeling aggrieved and dissatisfied with the impugned judgment and order dated 07.03.2014 passed by the learned Income Tax Appellate Tribunal, Ahmedabad Bench 'D', Ahmedabad (hereinafter referred to as "Tribunal") in ITA No.2558/Ahd/2013 for the assessment year 200607, the appellant - assessee has preferred the present Tax Appeal requesting to consider the....

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.... - assessee is that though a specific ground was raised before the learned Tribunal that the reasons to reopen the assessment were recorded by one officer and the notice under section 148 of the Income Tax Act, 1961 was by another officer and therefore, the reassessment proceedings has been vitiated, has not been dealt with by the learned Tribunal. It is submitted that even the decision which was ....

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.... ground which was raised before the learned Tribunal and the decision which was relied upon by the assessee has not been dealt with by the learned Tribunal, we are of the opinion that this is a fit case to remand the matter to the learned Tribunal to decide the appeal afresh in accordance with law and on merits and to deal with and decide all the grounds raised before the learned Tribunal includin....

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....l with the contention on behalf of the appellant that the reasons were recorded by one officer and the notice under Section 148 of the Income Tax Act, 1961 was issued by another officer and therefore, reassessment has been vitiated. We are making it very much clear that we have not expressed anything on merits whether the reassessment proceedings are valid or not more particularly the reassessment....