Court : Income Tax Appellate Tribunal ITAT Hyderabad
Reported in : (1987)20ITD768(Hyd.)
1. These two appeals are against the consolidated order of the Commissioner under Section 263 of the Income-tax Act, 1961 ('the Act') setting aside the assessments made by the ITO under Section 147 of the Act and directing him to redo the same afresh. The prejudice caused to the revenue was on account of the omission of the ITO to consider whether two businesses done under the names of Pillai Enterprises and Sagar Enterprises were the concerns of the assessee or not. We are asked to decide in substance one question of law, that is, (7) whether the Commissioner had jurisdiction to revise assessment order admittedly made under Section 147 and (2) a question of fact whether there were materials report that two businesses really belong to the assessee.2. The original assessments for these two years had a chequered history. The assessment for the year 1971-72 was made on 11-11-1971.The income declared by the assessee-firm was accepted as correct.However, this assessment was reopened under ...
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