2016 (10) TMI 1368

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....For the Revenue : Shri AR. V. Sreenivasan, JCIT ORDER PER BENCH: All these four appeals are filed by the assessee and these are directed against four separate orders of learned CIT (A) - II, Bangalore all dated 18.09.2013 for A. Ys. 1996 - 97, 1997 - 98, 1999 - 2000 & 2000 - 01. 2. All these appeals were heard together and are being disposed of by this common order for the sake of convenience.....

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....tribunal order dated 16.11.2006 as noted by the A.O. himself in first Para of his orders. As per the provisions of section 153 (2A), the orders are time barred and hence, we have to decide this aspect only as to whether the provisions of section 153 (2A) are applicable to orders passed u/s 201 (1) and 201 (1A). Learned CIT (A) has held that the provisions of section 153 (2A) does not apply to orde....

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.... High Court. We are of the considered opinion that if section 153 (2A) is applicable to order passed u/s 104 then there is no reason or basis to hold that it is not applicable to order passed u/s 201 and 201 (1A). Accordingly, by respectfully following this judgment of Hon'ble Rajasthan High Court rendered in the case of CIT vs. Jodhan Real Estate Development Corporation Pvt. Ltd. (Supra), we hold....