Direct reference to Supreme court u/s 257 in case of divergence of opinion amongst High court.
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....e directed that while scrutinising the orders of the appellate Tribunal for filing reference application u/s.256(1) they should instruct the Departmental Representatives to request the Tribunal to make a direct reference to the supreme court u/s.257 if there are conflicting decisions of two or more High Courts on any particular question of law. Further even in a reference sought by the assessee th....
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....not bring to charge an item of income falling under clause b in such reassessment proceedings initiated beyond the period of four years under clause(a). According to the court a notice of reassessment cannot be issued after the period of 4 years in respect of items of income falling under clause(b) and the ITO cannot assume jurisdiction indirectly by issuing a notice purporting to be under clause(....
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