2008 (3) TMI 51

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....edings initiated by the assessee were after invoking advisory opinion from the Assessing Officer. In our view, this aspect has been lost sight of by all the authorities including the Tribunal and the High Court. In this case there is no assessment under the Act. 2. In the afore-stated circumstances, we see no reason to interfere in the impugned judgment. However, we make it clear that we are keep....