1990 (3) TMI 14

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....come-tax Act, 1961, at the instance of the Revenue, a direction is sought to refer the following questions of law for the opinion of this court : For the assessment years 1981-82 and 1982-83 : " 1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in holding that the Commissioner was not correct in directing the Income-tax Officer to add the e....

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....nistrative Commissioner, the Income-tax Officer was directed to consider and treat the entire cash credits appearing in the books of account for the assessment years 1981-82 and 1982-83 as the undisclosed income of the assessee under section 68 of the Income-tax Act. However, the Tribunal felt that the entire matter should be investigated in greater depth and detail and, in that view, while uphold....

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.... after complete investigation bearing in mind the directions given by the Administrative Commissioner regarding specific aspects. We understand this order as stating that the entire matter is at large before the Income-tax Officer and that in the course of the de novo proceedings, it would be open to him to examine all the aspects including the applicability of section 68 of the Income-tax Act to ....