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Assistant Commissioner of Income Vs. Fertilizer Traders [Alongwith

Court : Income Tax Appellate Tribunal ITAT Allahabad

Reported in : (2004)83TTJ(All.)473

..... it clear that the amount which is taxable as "undisclosed income" in the block assessment should fall within the scope and ambit of the definition expressly given in chapter xiv-b and the amount which is not covered by the said definition cannot be subjected to tax in the block assessment, even though declared as such by the assessee ..... entire working of peak (so made by the ao) which formed the basis of computation of undisclosed income for the purpose of assessment under section 158bc in the cases of the appellant and the other concerned namely fertiliser traders was subject-matter of dispute in first appeal before the learned cit(a), varanasi; (e) the learned cit(a), varanasi had adjudicated upon the entire controversy related to ..... existence so as to be amenable for revision by the cit under section 263 of the act and, since no authority can revise an order which is not in existence, the orders passed by the cit, central, kanpur on 28th march, 2001 revising the original assessment orders for block period dt. ..... the relevant part of facts, submissions advanced by the parties and that order is as under: 12.1 after giving our thoughtful consideration to the rival submissions, facts and circumstances of the present cases and the ratio of the various decisions (supra), we are of the opinion that so far as the doctrine of merger, even after the amendment of the provisions of section 263 is concerned, once any of the 'aspects' of an ' ..... in the matter of cit v.mahalakshmi textiles mills ltd. .....