Reopening assessments: request direct Supreme Court reference where High Court conflict exists on adding barred items. Instruction requires Commissioners to have Departmental Representatives request the Tribunal to make a direct reference to the Supreme Court where High Courts conflict on whether a valid reopening of assessment for one category permits bringing time barred items into charge; CsIT to issue instructions and DRs to seek such references, including when the assessee seeks a reference.
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Provisions expressly mentioned in the judgment/order text.
Reopening assessments: request direct Supreme Court reference where High Court conflict exists on adding barred items.
Instruction requires Commissioners to have Departmental Representatives request the Tribunal to make a direct reference to the Supreme Court where High Courts conflict on whether a valid reopening of assessment for one category permits bringing time barred items into charge; CsIT to issue instructions and DRs to seek such references, including when the assessee seeks a reference.
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