W.T.AS. NOS. 132/IB TO 136/IB OF 1997-98 versus W.T.AS. NOS. 132/IB TO 136/IB OF 1997-98
Assessment Appeal for AACITO - An appeal order can only be considered for issues that have not been finalized after a fresh review. Appeals from such a fresh review may only apply to matters that are not finalized. The AAC holding review is valid and the ITO should be instructed to re-calculate the revenue. It is not open to ITOs with Hindi loans whereas AAC 5 147 in the appeal against the new Assessment, while making a fresh assessment as per the AAC's order to review the legal status of proceedings under Section 147. Cannot examine the legality of proceedings under the Indian Income Tax Act, 1961
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