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    <title>2015 (11) TMI 650 - HIMACHAL PRADESH HIGH COURT</title>
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    <description>The limitation scheme under the Income Tax Act and Wealth Tax Act distinguishes a routine fresh assessment after an appellate setting-aside from an assessment made to give effect to a finding or direction in a court or appellate order; the latter is not confined by the ordinary limitation period. On the facts described, the assessment was completed only after disputes over the legal heirs and the nature of the estate were finally resolved in civil and writ proceedings, and the period during which proceedings were stayed by court orders was excluded. The assessment was therefore treated as one made in consequence of court determinations on status and ownership, not as a time-barred fresh assessment.</description>
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      <description>The limitation scheme under the Income Tax Act and Wealth Tax Act distinguishes a routine fresh assessment after an appellate setting-aside from an assessment made to give effect to a finding or direction in a court or appellate order; the latter is not confined by the ordinary limitation period. On the facts described, the assessment was completed only after disputes over the legal heirs and the nature of the estate were finally resolved in civil and writ proceedings, and the period during which proceedings were stayed by court orders was excluded. The assessment was therefore treated as one made in consequence of court determinations on status and ownership, not as a time-barred fresh assessment.</description>
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