2018 (1) TMI 144

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....he Court was delivered by T.S.Sivagnanam, J. ) Heard Mr.T.R.Senthilkumar, learned counsel appearing for the appellant/Revenue. 2.This appeal filed by the Revenue is directed against the order passed by the Income Tax Appellant Tribunal (ITAT) in I.T.A.No.1470/Mds/2016 dated 09.03.2017. 3.This appeal has been filed raising the following substantial questions of law: 1.Whether the ....

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....ssee did not submit correct details of carry forward losses during the course of either assessment u/s.143(3) or subsequent first reassessment u/s.147 of Income Tax Act, 1961? 4.Before we consider the above questions, it would be necessary to take note of the factual background in the matter. The assessee filed an appeal before the Tribunal against the order of the Commissioner of Income Tax (A....

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....d that the second reopening of the assessment was a clear change of opinion and therefore illegal. However, the Commissioner of Income Tax (Appeals) partly agreed with the assessee with regard to the submissions made pertaining to the assessment records and therefore allowed the assessee's appeal in part by remanding the matter to the Assessing Officer to examine the submission of the appellan....