2011 (3) TMI 1631

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....instance of the assessee  and is directed against an order of the Income-tax Appellate  Tribunal, "A" Bench, Kolkata, in I.T.A. No.183/Kol/2003 for the  assessment year 1996-97 thereby affirming the order of the  Commissioner of Income-Tax ( Appeals )under section 163 of the  Income-tax Act holding that the assessee is an agent in terms of  the said provision.   ....

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....ed by  limitation and as such, the other part of the orders quashing the  proceedings have attained finality.   Therefore, at the time of hearing of the appeal, we find that  the question whether the assessee was really an agent within the  meaning of section 163 of the Act has become academic and it is  rightly pointed out by Mr. Bajoria, learned Senior Counsel &n....