Element of discrimination in refusing benefits to assessee by AO, held HC.
Nov. 02, 2015
u/s 144/147 &10(26AAA), AO held assessee non-Sikkimese & denied benefit in tax. On writ HC held, element of discrimination in refusing benefits ,merely because assessment proceedings had already been initiated & best orders were passed for assessment years, overlooking clarification that same is applicable even in case of reassessment. Settled law that benevolent circulars providing administrative relief to assessee have to be given effect.-010552