1986 (3) TMI 115

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....eard together and disposed of by this common order for the sake of convenience. 2. The assessee is an AOP deriving income from securities and dividends. The assessment years involved in these two appeals are 1980-81 and 1981-82. 3. The only common ground taken in these two appeals states that the Commissioner (Appeals) should not have dismissed the appeals filed before him by the assessee on....

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....aken by it before the Commissioner (Appeals). 5. We have considered the contentions of both the parties as well as the facts on record. It is now well settled that there is no inherent right of appeal and such a right has to be specifically conferred by the express terms of the statute. The assessment orders have been passed under section 143(3) of the Act and so section 246(1)(c) is the releva....

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.... merely because the ITO says that the assessments are made on the basis of the returns filed by the assessee on the incomes declared therein as a protective measure. The remark of the ITO merely means that the ITO reserved the right to proceed against somebody else if permitted under the law. Such a remark cannot give rise to any grievance on the part of the assessee who has been assessed exactly ....