Reopening-s.143(1), 147 on incorrect facts in reasons

[rajul5234]

Guj. H.C. Inductotherm. SCA 858/2006 dt. 6/8/12.
court has not refered 4th contention of petitioner after stating three contentions. Fourth contention of incorrect figure, incorrect item, incorrect section of deduction, incorrect case law applied just to assume jurisdiction u/s 147 is not refered. Mercantile system followed since inception in 1990 for warranty claim supported in addition by Rotorock(S.C.) ratio is not mentioned though specific ground in writ is there which was seriously pressed since the same is not even disputed in Affidavit in Reply by Revenue.
Hence, I have recommended filing of SLP to S.C. since if such reasons recorded are approved, proviso to s.147 is otiose.
R. K. Patel