back to the file of the ITO with a direction to reframe the issue in accordance with law with advertence to the observations made above ... back to the file of the ITO with a direction to reframe the issue in accordance with law. The brother Accountant Member has thus been
gave as limited mandate to the AO to examine two specific issues and reframe the assessment. It is only for the limited purpose, the assessment ... limited purpose of enabling the AO to examine the two specific issues and reframe the assessment. The view taken by the Tribunal in that regard
back to the file of the ITO with a direction to reframe the issue in accordance with law with advertence to the observations made above ... back to the file of the ITO with a direction to reframe the issue in accordance with law. The brother Accountant Member has thus been
question whether certain issues could be treated as preliminary issues should be decided at the time of framing of the issues and this aspect ... issues as preliminary issues. Nor have I been impressed by the plea that the respondents want recasting of the issues altogether and that issues framed
Consequent to above ITAT order, AO proceeded to reframe the issues
and instead of confining his order to the quantum which was the subject
matter ... rightly held that the AO should have restricted the reframing of issue to the
above extent. We uphold his orders. Consequently, we dismiss the revenue
aside this issue alone and directed
the AO to reframe this issue and to conduct a detailed enquiry and examine and to pass
order. Aggrieved ... same the assessment is set aside on this limited issue
to be reframed by the Assessing Officer after detailed enquiry and examination and
after giving
matter to the file of the assessing officer for redeciding the issue and
reframing the assessment in accordance with law, this ground of the
Revenue ... matter to the file of the
assessing officer for redeciding the issue and reframing the
assessment, this penalty appeal has become infructuous, and on that
Tribunal (supra), wherein the Hon'ble Tribunal have gone into the issues groundwise and have partly allowed the assessee's appeal giving ... case.
7. Further in order to make the issue concise one, reframe the issue to be decided by the Bench the issue involved pertains
with the justifications advanced by the
assessee. The CIT noted that the issue regarding disallowance or
otherwise of provision towards asset held for disposal ... aside
the assessment order in respect of the aforesaid issue for reframing the
assessment. The relevant para of the order of the CIT is reproduced
parties and carefully gone through the
appeal. We find that the following issues have been raised by the
appellant and Revenue, which are stated below ... three Judge Bench decision in
Gujarat Fluroro Chemicals (supra).
The Issues are reframed as under;
(1) What is the relevant date for computing interest