TaxTMI 
TaxTMI 
2006 (3) TMI 83
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....ening the assessment were recorded and disclosed by the Assessing Officer on June 2, 2005. There is no dispute that the reasons were received by the petitioner-company on that day itself. In October 2005, it moved this court by filing a writ petition against steps taken by the authorities for transferring all its cases with a view to centralising its tax matters. Certain interim order was made. Notice under section 142 was issued on January 17, 2006. On January 31, 2006, it submitted its objections to the reasons recorded and disclosed in support of reopening of the assessment. On February 13, 2006, it submitted further grounds of objections. In the decision dated February 16, 2006, the Assessing Officer recorded that the objections of the....
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....essment order an appeal can be preferred. To this, counsel for the petitioner-company submits that in view of the provision of law existing today (section 251(1)(a)) the appellate authority has no power to remit the matter to the Assessing Officer for determining the question of jurisdiction. I am unable to appreciate the manner in which the Assessing Officer proceeded with the matter. What he actually wanted to mean by his decision dated February 16, 2006, is not clear. In view of the objections submitted by the petitioner-company raising the question of jurisdiction, and in the face of the apex court decision in GKN Driveshafts (India) Ltd. v. ITO reported in [2003] 259 ITR 19 on receipt of the objections from the petitioner-company, he ....