Law: Income Tax Act, 1961

Section: 263,144,158BD,132

JUDGMENT R. Sudhakar, J. - T.C.(A) Nos.247 and 248 of 2014 are filed challenging the order of the Income Tax Appellate Tribunal 'C' Bench, Chennai, dated 19.11.2013 made in I.T.(SS) A.Nos.14/Mds/2012 and 14/Mds/2013 for the block assessment years 1991-1992 to 2000-2001 and 2001-2002 (part), raising the following questions of law: T.C.(A) No.247 of 2014: "(i) Whether, on the facts and circumstances of the case, the Tribunal was right in quashing the revision order passed under Section 263 of the Act on the ground that the original assessment order made under Section 144 read with Section 158BD of the Act itself was quashed as ab initio void? (ii) Whether, on the facts and circumstances of the case, the Tribunal was right in quashing the revision order passed under Section 263 of the Act, when the assessee has not produced any evidence for claiming 50% of commission receipt as expenditure to earn such commission income?" T.C.(A) No.248 of 2014: "(i) Whether, on the facts and circumstances of the case, the Tribunal was right in quashing the block assessment as time barred, when there is no time limit prescribed in the Income Tax Act either for recording of satisfaction note or issuing notice under Section 158BD of the Act? (ii) Whether, on the facts and circumstances of the case, the Tribunal was right in following Special Bench judgment in the case ofManoj Aggarwal v. Dy. CIT 113 ITD 377 (Delhi) which is not applicable to the facts of the present case and clearly distinguishable? (iii) Whether, on the facts and circumstances of the case, the Tribunal was right in cancelling the block assessment without adjudicating the grounds of appeal raised before it which is contrary to the ratio of the judgment of the Madras High Court in the case of South India Surgical Co. (P.) Ltd. v. Asstt. CIT [2003] 263 ITR 5?" 2. T.C.(A) No.502 of 2014 is filed by the Revenue challenging the order of the Income Tax Appellate Tribunal 'A' Bench, Chennai, dated 13.3.2013 made in I.T.(SS) A.No.16/Mds/2012 for block assessment years 1991-1992 to 2001-2002, raising the following question of law: "Whether, on the facts and in the circumstances of the case, the Tribunal was right in quashing…

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