1996 (2) TMI 95

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.... and the following two questions of law have been referred by the Tribunal before this court for answer, which read as under : " (1) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in admitting the additional grounds of appeal ? (2) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the assessments wer....

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.... paid by the assessee whether before or after the assessment, be kindly directed to be refunded. Thus, this additional plea of limitation was permitted by the Tribunal and the Tribunal ultimately passed an order on May 22, 1986, and allowed the appeals. Thereafter, an application for rectification under section 254(2) of the Income-tax Act was filed and it was pleaded that the additional grounds s....