1988 (8) TMI 40

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....ws : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in allowing the assessee's appeal on the ground that the delay in reopening the excess profits tax proceedings has not been properly explained in spite of the fact that there was no time limit for initiation of the action provided under the Excess Profits Tax Act, 1940 ?" Rule was issued in this application ....

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....e not found favour with the Tribunal and do not appeal to us also. It is true that there is no period of limitation fixed by the statute but the approach of this court, although indicated in a matter involving penalty, may also apply to reopening of excess profits tax assessments. Excess profits tax is a charge different from the ordinary rate of tax. The difficulties which may be faced by an asse....