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TMI Blog2023 (8) TMI 109X X X X Extracts X X X X X X X X Extracts X X X X ..... .Justice Mohammed Shaffiq For the Petitioner : Mr.N.Sudalaimuthu For the Respondent : Mr.M.Siddharthan Additional Government Pleader ORDER This Writ Petition is filed challenging the impugned order dated 22.04.2022 for the assessment year 2007-08 on the premise that the same is barred by limitation. 2. It is submitted by the learned counsel for the petitioner that the petitioner was a manufac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g of objections with supportive documents, the impugned order has been passed. 4. The original assessment order dated 24.10.2013 although refers to Section 22(2) of the Act, it appears that the same cannot be traced to Section 22(2) of the Act in view of the fiction contained in the proviso to Section 22(2), which provides that all assessments from the assessment year 2006-07 till 2010-11 shall b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment. In the present case, the original assessment is deemed to have been made in terms of Section 22(2) of the Act on 30.06.2012. In view of the same, any assessment traceable to Section 27 of the Act ought to have been initiated on or before 30.06.2018. Though this Court is conscious that issuance of notices would be sufficient for reckoning the period of limitation and it may not require pas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inance Ltd., reported in (2007) 7 SCC 215: "20.....The revisional jurisdiction having, thus, been invoked by the Commissioner of Income Tax beyond the period of limitation, it was wholly without jurisdiction rendering the entire proceeding a nullity." ii) ITW Signode India Ltd., vs. CCE reported in (2004) 3 SCC 48: "69. The question of limitation involves a question of jurisdiction. The find ..... X X X X Extracts X X X X X X X X Extracts X X X X
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