Held, that the assessee had filed objections to the reopening which had not been disposed of by the Assessing Officer by way of a separate order before framing the assessment. The assessment order was quashed. Tribunal also held, that the tax effect in the Revenue’s appeals was below Rs. 20 lakhs. Therefore, the appeals were to be dismissed as not maintainable in terms of Central Board of Direct Taxes Circular No. 3 of 2018, dated July 11, 2018 (2018)) 405 ITR (St.) 29). (AY.2001-02, 2003-04, 2004-05)
ITO v. Allied Instruments Pvt. Ltd. (2022) 93 ITR 555 (Mum.)(Trib.)
S. 147 : Reassessment-Failure to dispose objections by passing separate order-Reassessment not valid-Tax effect less than 20mlakhs-Appeal of revenue dismissed. [S. 143(3), 148]