1996 (1) TMI 24

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....n 256(2) of the Income-tax Act, 1961, the Revenue has prayed that the Tribunal may be directed to submit the statement of the case and refer the following questions of law for the opinion of the High Court : " (1) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally justified in annulling the assessment made under section 147/148 of the Incom....

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.... of all the facts and circumstances of the case. While deciding the case, the Tribunal has relied upon the judgment of the Supreme Court. The Tribunal also held that since the original assessment proceedings have got barred by time for both the assessment years, the fresh assessment proceedings initiated for the same assessment years, were invalid because they were completed on the basis of the fr....