2017 (10) TMI 108

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....e Petitioner : Mr. M. MD. Ibrahim Ali For Respondents : Mr. A.P.Srinivas ORDER Heard learned counsel for the parties. 2.The petitioners in all these Writ Petitions have come forward with these Writ Petitions for issuance of Writ of Declaration to declare Sections 115 WA(2) and 115 WB(1) and 115 WB (2) of the Income Tax Act, 1961 as introduced by the Finance Act, 2005 ultra vires of Art....

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....e learned counsel for the Revenue expressed an apprehension that in the event the Hon'ble Supreme Court uphold the provisions as being a valid piece of legislation, then the assessees like the petitioners should not plead that the action that may be initiated by the Department or in the process of being initiated, is barred by limitation. 6.The Revenue need not have any apprehension in this....