2007 (7) TMI 178

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.... involved in all these appeals are common, by consent of counsel for the parties to the Its , the matter is taken up for hearing, though they are posted for admission before this court today. 2 Aggrieved by the orders of the reassessment for the assessment years 11993-94, 1994-95 and 1996-97, passed by the assessing authority in case of his powers under section 147 of the Income-tax Act, 1961, ....

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....rst appellate authority that the assessee's representative has not agitated the disallowance of interest made by the assessing authority for the aforesaid assessment years. In the words of the first appellate authority "At the time of hearing the authorised representative has not agitated the disallowance of interest made by the Assessing Officer at Es. 48,480 in  the assessment years 1993....

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....ner, the assesses cannot be an aggrieved person and, therefore, could not have filed any appeals before the Tribunal, though technically an appeal might lie, such an appeal would be clearly unarguable. 6 The Tribunal, after considering the case of the assesses, had disposed of the appeals, by its order dated October 9, 2006. Aggrieved by the aforesaid order, the assesses is before us in these a....

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....hority that he is not agitating the appeals for the assessment years 1993-94, 1994-95 and 1996- 97, the assessee could not have filed any appeals before the Income-tax Appellate Tribunal. In our opinion, Shri George K. George, learned standing counsel for the Revenue is justified in saying so, the reason being that the assessee, having not objected to the orders passed by the assessing authority o....