2017 (5) TMI 215

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....eal filed by the assessee arises against the order dated 09/09/2015 passed by the ld. Pr. CIT, Kota pertaining to the A.Y. 2012-13, wherein the assessee has raised following grounds of appeal: "1. That the impugned order u/s 263 dated 09.09.2015 is bad in law and on facts of the case for want of jurisdiction and for various other reasons and hence the same may kindly be quashed. ....

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....nding being perverse, the impugned action is bad in law without jurisdiction and being void ab initio, the impugned order u/s 263 of the Act kindly be quashed. 3. That the ld. Pr. CIT Kota is erred in law as well as on the facts of the case in setting aside the assessment to be made afresh with the direction to re-examine the issue in the light of his observation. The same is being purely....

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....e same was not accepted by the ld. Pr. CIT. He proceeded to revise the order by setting aside the order of the Assessing Officer and restoring the assessment for framing de novo assessment to the Assessing Officer. 3. Being aggrieved by the order of the ld. Pr.CIT, the assessee is in appeal before us. 4. Ld. Counsel for the assessee has vehemently argued that the action of the ld. Pr.CIT is ....

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....ble properties. It is also noticed by the ld. Pr.CIT that as per balance sheet filed by the assessee for the assessment year 2011-12, the value of the two properties were as under:- Sharma Ice Factory Rs. 3,67,495/- Building S-33, MBS Nagar Rs. 17,10,000/-   (8,10,000 + 9,00,000) It is the case of the assessee that a valuation report was submitted showing year wise constr....