1996 (1) TMI 115

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....rged and considered by us as to whether, on the facts and circumstances of the case, the proceedings of the Deputy Commissioner passed after the expiry of over eight years from the end of the relevant assessment year would create a bar of limitation, except consideration and decision of the above question of limitation, no other question would require consideration. This is because, in the earlier judgment dictated by us today before the recess in Income-tax Reference No. 201 of 1988 (Rajagiri Rubber and Produce Co. Ltd. v. CIT [1996] 219 ITR 611) we have considered the question of limitation threadbare and in necessary detail, to the effect that the bar of limitation in the matter of exercising suo motu revisional powers under section 34 o....

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....n the petitioner-assessee on April 1, 1991, and is consequently exercised, as stated above, by the order dated May 20, 1991. It needs to be stated that although in Tax Revision Case No. 166 of 1992 the assessment year is 1980-81, the assessment order is the same as Tax Revision Cases Nos. 38 and 103 of 1992, to be February 13, 1984. Even as regards the initiation of action under section 34 of the old Act, the dates are also similar being a notice dated March 30, 1991, served on the petitioner on April 1, 1991, resulting in the order under section 34 having been passed on December 13, 1991. Similarly although in Tax Revision Case No. 256 of 1992 the assessment year is 1981-82, the assessment order is passed on the same day February 13, 1984....