2016 (6) TMI 373

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....adhir Gupta ORDER Per B. R. Baskaran, AM The appeal filed by the assessee is directed against the order dated 20.12.2013 passed by learned CIT(A)-14, Mumbai. 2. Grounds of appeal relate to the demand raised u/s. 201(1) and interest charged u/s. 201(1A) of the Act. 3. The assessee has also raised a ground urging that the order passed by the Assessing Officer is barred by limitation. ....

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....passed order on 28.3.2011 raising demand u/s 201(1) and charging interest u/s 201(1A) of the Act. The Ld CIT(A) also confirmed the order of the AO on majority of the issues, but gave partial relief with regard to the period for computing interest u/s 201(1A) of the Act. 5. In the appeal filed before us challenging the order passed by Ld CIT(A), the assessee has urged a legal issue before us, i.....

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....)(365 ITR 560). The above said decision has been rendered by the Hon'ble High Court on the appeal filed by the revenue challenging the decision rendered by the Special bench. The Special bench of Tribunal had rendered its decision on the issue of limitation period as under:- (a) The proceedings u/s 201(1) can be initiated in the extended period of six years from the end of the relevant....

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....he decision (para (a)) and the Revenue challenged the second part of the decision (para(b)) supra. The Hon'ble High Court disposed of the appeal filed by the revenue by upholding the view taken by the Tribunal in para (b) supra with regard to the time limit for completion of the proceedings. It was stated that the appeal filed by the assessee is still pending before the Hon'ble High Court of Bomba....