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    <title>2018 (6) TMI 1272 - ITAT HYDERABAD</title>
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    <description>Timely service of notice under section 143(2) and the computation of limitation were the central issues, with the discussion also addressing whether time covered by High Court writ proceedings and stay orders could be excluded. The first appellate authority had quashed the assessments for want of a notice within the prescribed period and held that section 292BB did not cure the defect. The Revenue then argued that the High Court&#039;s interim and final orders linked to the special-audit proceedings affected the limitation period, with reliance on the exclusionary principle in Explanation (iii) to section 153. Because the scope and effect of those orders had not been fully examined, the matter was remitted for fresh adjudication.</description>
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      <description>Timely service of notice under section 143(2) and the computation of limitation were the central issues, with the discussion also addressing whether time covered by High Court writ proceedings and stay orders could be excluded. The first appellate authority had quashed the assessments for want of a notice within the prescribed period and held that section 292BB did not cure the defect. The Revenue then argued that the High Court&#039;s interim and final orders linked to the special-audit proceedings affected the limitation period, with reliance on the exclusionary principle in Explanation (iii) to section 153. Because the scope and effect of those orders had not been fully examined, the matter was remitted for fresh adjudication.</description>
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