TMI Blog2014 (7) TMI 560X X X X Extracts X X X X X X X X Extracts X X X X ..... enue - Revenue is not challenging the orders of the Tribunal dated 23-12-2013 and has decided to accept the same - there is a finding of the Tribunal that the proceedings were time barred - there was an inherent lack of jurisdiction to take cognizance of the proceedings since they were time barred - there is no point in continuing with the proceedings whereby the Commissioner taking suo-motu actio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case are that the appellant is an income tax assessee running a bonded warehouse. On 23-02-2005 search and seizure operations were carried out in the premises of the assessee in terms of Section 132 of the Income Tax Act, 1961 (hereinafter referred to as the Act). Pursuant to the said search and seizure operations, the Assessing Officer issued notice under Section 153A of the Act calling upon the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er of Income Tax, Shillong took suo-motu cognizance under Section 263 of the Act. Before the appeals filed by the assessee could be decided, the Commissioner of Income Tax vide his order dated 04-06-2008 came to the conclusion that the assessment orders passed for each of the assessment years were erroneous and prejudicial to the interest of the revenue and accordingly, set aside the orders of ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Appellate Tribunal vide its judgment dated 23-12-2013 allowed the appeals of the assessee and held that all the assessment orders for the assessment years, i.e. 2000-2001 to 2004-2005 were barred by limitation and accordingly, the same were quashed. 6. This fact was brought to our notice by learned counsel for the appellant on 18-03-2014 and we had directed Mr. S. Sarma, learned coun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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