TMI Blog2016 (10) TMI 1368X X X X Extracts X X X X X X X X Extracts X X X X ..... ssed u/s 201 (1) and 201 (1A). It is noted by him in Para 3.2 of his order that as per the A.O. Section 153 (2A) of the Act applies to only orders enumerated therein and does not cover orders passed u/s 201 (1) and 201 (1A). CIT (A) has reproduced the provisions of section 153 (2A) and since section 201 is not refereed therein, he confirmed the assessment order on this aspect. Now we examine th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ER AND SHRI A. K. GARODIA, ACCOUNTANT MEMBER For the Assessee : Shri Nageshwar Rao, Advocates 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. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isputed that the impugned orders passed by the A.O. on 30.03.2011 u/s 201 (1) and 201 (1A) were passed to give effect to the 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 or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... time barred and the tribunal held in that case that it is time barred and this tribunal order was upheld by Hon ble Rajasthan 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 b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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