Appeal Effect to the order of CIT (A)

This query is : Resolved 

27 June 2011 One assesee who filed an appeal and his appeal was partly allowed by ITAT and for balance addition the same were set aside in the year 2002. Now, the same seems to be barred by limitation. What is the reamdy avalable to that client?.

The AO also levied Penalty u/s 271(1)(c) in 2000 for Rs. 15,00,000/- based on the various additions made by him and the Assessee has not filed any appeal against the order. What is the remade with the assessee.

C. A. S. S. AGARWAL

27 June 2011 1) If A.O has not given effect to ITAT order, try a writ and OP before the jurisdictional High Court on that ground.
2) File an appeal before the CIT(Appeals),with a condonation of delay, against the 271(1)(C) order emphasizing relief given by ITAT.

27 June 2011 None of these have worked. As the set aside matter is regarding verification of cash credit related to assessment year 1979-80 and most of the cash creditor have expired or not traceable. In these circumstances what to do.

271(1)(c) penalty as no appeal was filed the A. O. says he cannot help.


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