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2002 (11) TMI 79 - HC - Income Tax"1. Whether, on the facts and in the circumstances of the case, the Tribunal erred in holding that the burden was on the assessee to prove by cogent and convincing evidence that the recipient had actually paid tax on the income or the income had been held to be non-assessable? - 2. Whether, on the facts and in the circumstances of the case, the Tribunal ought to have held that whatever burden lay on the assessee for not being regarded as an assessee in default under section 201 had been discharged? - 3. Whether the Tribunal erred in holding that the proceedings initiated under section 201 of the Income-tax Act, 1961, were not barred by limitation?" - We do not wish to answer the questions referred to us. - No explanation has been given as to why the Inspecting Assistant Commissioner did not take appropriate steps. We, therefore, return the reference unanswered.
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