Binding precedent on section 201(1) limitation and Tribunal review defeated the Revenue's challenge.

Binding precedent on limitation for orders under section 201(1) in the case of a non-resident was accepted, and the Revenue did not dispute that position; the challenge on limitation was therefore answered in favour of the assessee. The contention that the Tribunal's order was perverse for not examining the merits of the section 201(1) order also failed, because the questions of law were treated as covered by precedent. The appeal was dismissed and the Tribunal's decision was left undisturbed, with the substantial questions of law decided against the Revenue.

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Issues: (i) Whether the order passed under section 201(1) of the Income-tax Act was barred by limitation on the basis of a reasonable time limit in the case of a non-resident. (ii) Whether the Tribunal's order was perverse for not considering the merits of the order passed under section 201(1) of the Income-tax Act.

Issue (i): Whether the order passed under section 201(1) of the Income-tax Act was barred by limitation on the basis of a reasonable time limit in the case of a non-resident.

Analysis: The questions raised were stated to be covered by binding precedent of the Delhi High Court, and the Revenue did not dispute that position.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

Issue (ii): Whether the Tribunal's order was perverse for not considering the merits of the order passed under section 201(1) of the Income-tax Act.

Analysis: The appeal was disposed of on the basis that the questions of law stood covered by precedent.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

Final Conclusion: The appeal was dismissed and the Tribunal's decision was left undisturbed, with the substantial questions of law decided against the Revenue.

Ratio Decidendi: Where the questions raised are covered by binding precedent and are not disputed, the appellate challenge fails.

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