2017 (3) TMI 891

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....i/b Atul Jasani P.C. : 1. This Appeal under Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 31st October, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of block period for Assessment Year 199697 to 200102 and part period from 1st April, 2001 to 14th March, 2002. 2. The Revenue urges the following reframed substan....

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....ta was relied upon by the Assessing Officer to conclude that sales of Attar Hina (AH) shown by the appellant to claim deduction under Section 80 IA of the Act was in fact bogus. On the above basis the Assessing Officer by order dated 31st March, 2004 completed the Assessment under Section 158 BC of the Act. 3. In appeal the Commissioner of Income Tax (Appeals) [CIT (A)] on facts by the order date....

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....e facts of this particular case as there was no undisclosed income in terms of Section 158B of the Act and it cannot be subject matter of block assessment under Section 158BC of the Act. The impugned order placed reliance upon the decisions of this Court in Commissioner of Income Tax (A) vs. Vikram A Doshi 127 Taxman Page 513 and Commissioner of Income Tax vs. Shamlal Balram Gurbani 249 ITR Page 5....