TaxTMI 
TaxTMI 
TaxTMI 
1989 (2) TMI 95
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....ncome-tax Act, 1961 (for short "the Act"), relating to the assessment years 1983-84 to 1985-86 and arise from a common order passed by the Income-tax Appellate Tribunal,'D' Bench, New Delhi. The assessments for the disputed years were made under section 143(1) of the Act accepting the returned income. These assessments were set aside under section 263 by the Commissioner of Income-tax, to be mad....
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....s it was prejudicial to the interests of the Revenue ? 2. Whether the Tribunal's order is wrong on facts and in law in taking into consideration incorrect facts and facts not relevant to the case and ignoring relevant facts and findings in the orders under appeal ? " The assessments were set aside basically on three grounds (i) that the Income-tax Officer has accepted the initial capital inves....
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....ssee had not wound up her business of advancing loans, as held by the Commissioner. In fact, the assessee was being assessed for future years including the year 1987-88. The Tribunal also referred to a circular issued by the Directorate of Inspection (Income and Audit) being Circular No. 176 dated August 26, 1987, addressed to all the Commissioners of Income-tax with regard to assessments framed u....
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.... was declared from some unknown business but the nature and premises were clearly indicated and it is to project this aspect that statement of income for the assessment year 1982-83 has been noticed in this order. Further, not only the business continued after the loans of Rs. 10,000 and Rs. 29,000 but the income also has been substantially higher." Learned standing counsel, appearing for the Re....