2012 (6) TMI 823

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.....S. Pandya, Sr. D.R. For the Respondent : Shri Vartik R. Chokshi, A.R. ORDER PER : D.K. TYAGI, JUDICIAL MEMBER These two appeals have been filed by the assessees against the separate orders passed u/s 263 of the Act by ld. CIT dated 09.03.2012 on similar facts. The grounds of appeals in both the appeals are also common, so for the sake of convenience both the appeals are being disposed....

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....ncome was filed. The return income filed by the assessee was accepted by the A.O. vide assessment order dated 7th May, 2010 passed u/s 143(3) of the Act. 3. Subsequently, on 12th April, 2011 the CIT, Ahmedabad-V issued a show cause notice u/s 263 of the Act intimating that as per the proviso to Section 54EC(1), the investment made in long term specified assets during any financial year should n....

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....t order may be reframed in accordance with law. 4. Aggrieved by this order of ld. CIT, these appeals has been filed before us. At the time of hearing ld. counsel of the assessees' only grievance was that ld. CIT, while directing the A.O. to reframe the assessment order in accordance with law, has also made certain observations in his order on the issue of allowability of deduction u/s 54EC of t....