2017 (8) TMI 1684

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..... : Alok Mathur For the Respondent : Namit Sharma ORDER 1. Heard Sri Alok Mathur, learned counsel for appellant and Sri Namit Sharma, counsel for respondents. 2. All these appeals have arisen from common judgment dated 28.04.2015 passed by Income Tax Appellate Tribunal, Lucknow Bench, Lucknow (hereinafter referred to as "Tribunal") in Income Tax Appeal no. 846/Lko/2014 relating to (Assessment Y .....

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..... Mass Awash Private Limited Vs Commissioner of Income Tax (International Taxation) and another. In para 16 of judgment, this Court formulated question no. 3 as under: " Whether there is any period of limitation which can be applied in respect of proceedings under Section 201(1)/201(1A) of Act, 1961." 5. The aforesaid question after examining various authorities on the subject has been answered .....

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..... State of Orissa Versus Debaki Debi (supra), S. B. Gurbaksh Singh Versus Union of India (supra) and CST Versus Halari Store (supra), Court said that a power conferred without any time limit, if not exercised within reasonable time, unreasonable delay in exercise may effect its validity. However, it also held that what would be reasonable time is not to be fixed by Court since delay depends upon fa .....

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