Case Law Details
Case Name : Shri Ramesh Salecha HUF Vs. ITO (ITAT Mumbai)
Related Assessment Year : 2011-12
Courts :
All ITAT ITAT Mumbai
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Shri Ramesh Salecha HUF Vs. ITO (ITAT Mumbai)
Revenue could not produce before us any evidence to show that notice under sections 143(2) has been issued or served to the assessee the re-assessment made under sections 143(3) read with section 147 is void ab-initio in view of the above decisions of the Honorable Allahabad High Court in the case of ACIT v. Greater Noida Industrial Development Authority (supra) and the Honorable Delhi High Court in the case of ACIT v. Geno Pharmaceuticals (supra). Thus, respectfully following the said decisions we hold that the re-assessment made under secti...
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OFFHAND
In one’s longstanding firm conviction, the principal issue is centered on a very basic, rather elementary enactment; interpretation of which ought not to have posed any genuine difficulty, upfront. As such, by any sane thinking, the issue ought to have been, instead of being prolonged for years, regarded as clinched – fully finally settled long, long ago. A mere cursory look through the ITAT Order , particularly the host of case law cited and the long winding arguments of the Revenue, following beaten track, by reason of which the ITAT was obligated to discuss at such a great length , but ultimately to reach the only possible conclusion, rightly so in assessee’s favor, might have left anyone dazed and in utter bewilderment, over the rock bottom quality of the ‘legal system’, in its comprehensive sense, and the tax regime, in place !