2017 (6) TMI 22
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....ich was not even prayed by the assessee in its Cross Objections, as the assessee was aggrieved by the order of this CIT(A) to the extent that it has not decided the grounds raised by its regarding various additions, whereas the Tribunal has proceeded much ahead and has deleted those additions? (ii) Whether the Tribunal was justified in holding that in reassessment fishing inquiries cannot be made, whereas it is a settled proposition that once the reassessment proceedings are pending, the entire assessment is open and not confined to scope of reasons recorded by the Assessing Officer?" 3. However, the issue is squarely covered by the decision of this Court in the case of S. Kasliwal & Co. vs. The Assistant Commissioner of Income Tax in ....
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....oof of clearance at any Customs Station was on the assessee, and that since there were no documents produced recording any clearance at any Customs Station, the exemption was denied under Section 80HHC of the Income Tax Act. 6. The explanation (aa) of sub-section (4C) of Section 80HHC of the Income Tax Act reads as follows: "(aa) "export out of India" shall not include any transaction by way of sale or otherwise, in a shop, emporium or any other establishment situate in India, not involving clearance at any customs station as defined in the Customs Act, 1962 (52 of 1962)." 7. In the present case, the assessee had produced the 'Sale to Foreign Tourists Voucher', which not only recorded the name and address of the customers (....