2013 (3) TMI 74

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....clarification/recall/modification of the judgment and order dated 12.10.2006 passed by this Court has been filed on the ground that the observations made in the last but one paragraph of the judgment are beyond the subject matter of dispute before the Court and the same ought to be recalled. The Income Tax Appellate Tribunal, Delhi under Section 256(1) of the Income-tax Act, 1961, hereinafter r....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rge the limitation either for the reopening of the assessments or for their completion ?" The Court while answering both the questions in favour of the assessee and against the Revenue had made the following observations in last but one paragraph. "We have already held that clause (a) of Section 147 is not attracted in the present case. By virtue of the award given by the Avas Tribunal on 2....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....er of decisions have been cited by the learned counsel for the applicant on the question that this Court while answering a Reference has to confine itself to the questions as referred to and cannot travel beyond it. We may mention here that there cannot be any dispute about the proposition advanced by the learned counsel for the applicant as it is well settled that this Court has to confine itself....