https://www.taxtmi.com/caselaws?id=213456 The court allowed the petition, quashing the order treating the petitioner as an agent of a foreign company for assessing capital gains. The court ruled in favor of the petitioner, emphasizing that the notice issued was beyond the two-year limitation period under Section 149(3) of the Income Tax Act, 1961. The court did not delve into the first legal argument raised by the petitioner, ultimately setting aside the impugned order under Section 163 without awarding costs. en-us Wed, 30 Nov 2011 00:00:00 +0530 Mon, 10 Dec 2012 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213456 The court allowed the petition, quashing the order treating the petitioner as an agent of a foreign company for assessing capital gains. The court ruled in favor of the petitioner, emphasizing that the notice issued was beyond the two-year limitation period under Section 149(3) of the Income Tax Act, 1961. The court did not delve into the first legal argument raised by the petitioner, ultimately setting aside the impugned order under Section 163 without awarding costs. Case-Laws Income Tax Wed, 30 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213456