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2022 (11) TMI 832
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....ak Mitra, Adv....for appellant Mr. J. P. Khaitan, Sr. Adv. Mr. A. Gupta, Adv. Mr. I. Banerjee, Adv....for respondent GA/1/2022 The Court :- We have heard Mr. Tilak Mitra, learned standing Counsel for the appellant and Mr. J. P. Khaitan, learned Senior Counsel for the respondent. There is a delay of 210 days in filing this appeal. We have perused the affidavit filed in support of the petit....
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.... ii. WHETHER the Learned Tribunal has erred in deciding the present case relying on the facts and circumstances of the assessee's own case for the assessment year 2010-2011, ignoring the facts that each and every assessment is distinct and is made on different facts and circumstances ? We have heard Mr. Tilak Mitra, learned standing Counsel for the appellant and Mr. J. P. Khaitan, learned Sen....
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....n of law is that each and every assessment is distinct and different and, therefore, the learned Tribunal ought not to have followed the decision in assessee's own case for the assessment year 2010-2011. Though it may be true that each assessment year is an independent unit yet the theory of maintaining a consistent breach is well settled. This theory should be breached only if the department has ....