https://www.taxtmi.com/caselaws?id=18367 A plea that an assessment is barred by limitation goes to the root of the matter and may be raised for the first time as an additional ground of appeal. The Tribunal was therefore justified in admitting the limitation plea. The determination of limitation depended on the facts of the case, and where the issue is essentially factual, the finding will not be interfered with in reference proceedings. The Tribunal's conclusion that the assessments were time-barred was upheld, and both referred questions were answered in favour of the assessees. en-us Fri, 09 Feb 1996 00:00:00 +0530 Wed, 30 Sep 2009 13:58:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18367 A plea that an assessment is barred by limitation goes to the root of the matter and may be raised for the first time as an additional ground of appeal. The Tribunal was therefore justified in admitting the limitation plea. The determination of limitation depended on the facts of the case, and where the issue is essentially factual, the finding will not be interfered with in reference proceedings. The Tribunal's conclusion that the assessments were time-barred was upheld, and both referred questions were answered in favour of the assessees. Case-Laws Income Tax Fri, 09 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18367