contention of the Assessee on the ground that the
provisions of Section 153D of the Act, in its term, does
not require any such opportunity ... section (1) of section 153A or the assessment
year referred to in clause (b) of sub-section (1) of
section 153B , except with the prior
contention of the Assessee on the ground that the
provisions of Section 153D of the Act, in its term, does
not require any such opportunity ... section (1) of section 153A or the assessment
year referred to in clause (b) of sub-section (1) of
section 153B , except with the prior
have held that in the absence of specific provision in
Section 153D of the Income Tax Act, 1961, ['Act' for
short] the present ... learned Counsel
for the Assessee, bereft of the statutory
provisions in Section 153D of the Act cannot
bind the approving Authority, namely, the
Joint Commissioner
have held that in
the absence of specific provision in Section 153D of the
Income Tax Act, 1961, ['Act' for short] the present ... learned Counsel for the Assessee, bereft of
the statutory provisions in Section 153D of
the Act cannot bind the approving Authority,
namely, the Joint Commissioner
conducted under
Section 132 ibid."
19. Chapter XIV of the Income Tax Act, 1961 dealing with
the procedure for assessee comprising Section ... returns, enquiry,
assessment, best judgment assessment, time limits etc. Sections
153A to 153D of the Act deal with assessment procedure in case of
matter relating