Shri P.N. Parashar, Judicial Member - (1.) IN this appeal, against the order of Assistant Commissioner of INcome-tax (INvestigation), Kanpur, dated 28-11-1997, the assessee has challenged the assessment for the block period, completed under the provisions of Chapter XIVB of the INcome-tax Act. The block period is from 1-4-1994 to 28-11-1996.
(2.) This appeal was heard on priority basis as directed by the Hon'ble High Court of Judicature at Allahabad. The Hon'ble Court, vide its order dated 23-7-1999, has directed the Tribunal to decide the appeal by 15th September, 1999. In the grounds of appeal, initially, the assessee took as many as 46 grounds. As many of these grounds were argumentative in nature, an objection was filed on behalf of the Department on 19-4-1999 alleging that these grounds being in the nature of written arguments, either should not be allowed, or in the alternative, the assessee should not be allowed to make arguments, simultaneously.
(3.) THE appellant moved an application for admitting additional grounds. THEse are annexed with the application of the appellant dated 18-8-1999 as Annexure-B. THE additional grounds were admitted by the Bench vide order of the Bench dated 18-8-1999. A detailed order was passed in this regard on the application of the appellant dated 18-8-1999. However, as so many grounds were repeated and as the position was not very clear, the ld. counsel for the assessee was asked to consolidate and concise the original grounds as well as the additional grounds.;