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Assessment Order Fails to Follow Dispute Resolution Panel Directions, Appeals Allowed u/s 143(3) to Commissioner (Appeals.

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....The impugned assessment order though stated as an order under Section 143(3) r.w.s. 144C(13) is not an order in pursuance of the directions of the Dispute Resolution Panel, but an order of assessment simplicitor under Section 143(3) from which an appeal would lie to the Commissioner (Appeals).....