COMMISSIONER OF INCOME TAX Vs. THREE DEE EXIM

JUDGEMENT

(1.) THESE appeals are filed against the common order dated 25th September, 2009 of the Income Tax Appellate Tribunal (hereinafter referred to as the Tribunal) whereby cross-objections filed by the assessee for the assessment year 1999-2000 were allowed and consequently appeal of the Income Tax Officer, Ward 16(2), New Delhi (for short the Revenue) was dismissed. Vide this common order both the appeals are being disposed.

(2.) THE issue raised in the present appeal centered around a narrow compass. With the consent of the counsel for parties, we heard the matter finally and propose to dispose of the appeal on the following substantial question of law:

(3.) THE order of the AO was challenged in appeal before the Commissioner, Income Tax (Appellate) [CIT(A)] on as many as eleven grounds. One of the grounds on which the impugned order was passed and which is challenged before us was with regard to want of service of notice under Section 148 of the Act on the assessee before finalization of the assessment for the assessment year 1999-2000. The CIT(A) repelled this contention of the assessee with the following reasoning: