2014 (6) TMI 996

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....llant : NARASIMHA SARMA, ADV. JUDGMENT (Per the Hon'ble the Chief Justice Sri Kalyan Jyoti Sengupta) This appeal is sought to be preferred and admitted against the judgment and order dated 23.08.2013 of the learned Tribunal in relation to the assessment years 2003-2004 and 2004-2005 on the following suggested questions of law: i. In the facts and circumstances of the case, whethe....

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....available consequent to the Transfer Pricing Officer's order? It appears that the Assessing Officer wanted to reopen the assessment in relation to the aforesaid assessment years under Section 147 read with Section 148 of the Income Tax Act, 1961 (for short 'the Act'). Admittedly, the aforesaid attempt to reopen the assessment was made beyond the ordinary period of four years from the end of rel....