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1987 (7) TMI 11 - DELHI HIGH COURTExtract: .......f limitation under section 149(3) to hold the assessee as agent had expired owing to default on the part of the assessee, giving no opportunity to the Department to be able to treat the assessee as agent ? The Tribunal is, therefore, directed to submit the statement of the case and refer the aforesaid questions of law for the opinion of this court.
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