2005 (7) TMI 66

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....ellate Tribunal has referred the following question of law for the opinion of this court: "Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that mistakes in assessments completed under section 143(1) of the Income-tax Act, 1961, cannot be rectified by resorting to the provisions of section 154 of the Income-tax Act, 1961?" Heard learned counsel....

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....r is binding on the Revenue though learned counsel tried to contend that the said circular is not applicable to the old referred cases. However, he could not take his submission to a logical end. One fails to understand how the Revenue can contend that so far as new cases are concerned, the circular issued by the Board is binding on them and in compliance with the said instructions, they do not f....