Limitation for an assessment giving effect to appellate...

Limitation for an assessment giving effect to appellate directions runs from receipt or passing of the appellate order by the specified senior income-tax authorities, not from delivery to the Departmental Representative. Where no receipt date is recorded, internal transmission of a batch of orders does not establish earlier receipt, and the assessment may be treated as timely. Unexplained purchase expenditure cannot be added solely because suppliers did not answer summons when supplier existence, VAT verification, stock records, and corresponding sales support the transactions. The deletion of the purchase addition was sustained, while the Revenue's appeal and the assessee's cross-objections were dismissed.