2022 (3) TMI 302

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.... for the parties. 3. The W.P.(C) No.35820 of 2021 has been filed by the Petitioner No.1 along with three other Directors and Ex-Director of Petitioner No.1 company. Petitioner No.1 is M/s. Shiva Cement Ltd. having its Registered Office at P-25, Civil Township, Rourkela, Dist. Sundargarh, operating a mini cement plant at Telighana, Birigotoli near Kutra in the district of Sundargarh, Petitioner No.2 is its Director, Petitioner No.3 is the Ex-Director and Petitioner No.4 is also Director of the said Shiva Cement Ltd. The prayer in the present writ petition seeks mandamus to the opposite parties by proper disposal of the petitioners' applications dated 04.01.2021(available at page 126 of the Paper Book) and 29.10.2021(available at page 161 ....

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....prise the Court with regard to the stipulated period of limitation that would be applicable for completion of the Assessment Proceedings by the A.O. concerned in respect to the show-cause notices for the relevant years issued to the petitioners as detailed hereinabove. 8. At the time of resumption of hearing today, the learned counsel for the Revenue, upon instructions from the Department, very fairly concedes that the period of limitation for concluding the Assessment Proceedings under Section 153-A of the I.T. Act has been provided under Section 153-B which was in operation at the time of search on 24.9.2014 and not the period of limitation as substituted by the amendment with effect from 1.6.2016. It is not in dispute that as per the ....