2021 (1) TMI 1065

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....h. Ved Jain, Adv with Sh. Ashish Goyal, CA For the Respondent : Sh.Bhagwati Charan,Sr. DR ORDER PER SUCHITRA KAMBLE, JM This Miscellaneous Application is filed by the assessee in respect of order dated 23/10/2020. 2. The Ld. AR submitted that in Para 7 of the order dated 23/10/2020, the Rule quoted was 26 but the actual Rule is 27 of the Income Tax (Appellate Tribunals) Rules 1963. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....as pursuant to the MOU between the two companies and the copy of said MOU was submitted before the AO along with objections to the reasons recorded u/s 148. The appellant has also filed copy of said MOU in the paper book filed before me at page 96-102. On perusal of the MOU it is noticed that the same is signed by the director of the two companies. As per the clause 6(six) of the terms an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ted by the assessee nor any remand report was called by the CIT(A). 3. The Ld. DR submitted that these are the typographical and inadvertently mistakes. Emerging from the order dated 23/10/2020. 4. We have heard both the parties and perused the material available on record. There is inadvertent mistake in the Para 7 that of typographical and in Para 8 that of mistake regarding the facts of t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....between the two companies and the copy of said MOU was submitted before the Assessing Officer . On perusal of the MOU it is noticed that the same is signed by the Director of the two companies. As per the clause 6(six) of the terms and conditions of the MOU, the rolling mill business at Satharia which was being run by the assessee company was transferred to M/s Abhinav Steel Pvt. Ltd. Thus, the ob....