Court Emphasizes Need to Raise Limitation Issues for Adjudication; Petitioner Failed to Address Time Constraints.

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....Validity of assessment order - period of limitation - Limitation being a mixed question of law and fact, has to be necessarily raised by a party in order that the adjudicating authority applies its mind and renders a finding thereon. The petitioner has not offered any semblance of explanation as to why and for what reason it has failed to raise the issue of limitation - HC....