Assistant Commissioner Of Income Tax vs Shelf Drilling Ron Tappmeyer Limited on 8 August, 2025

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SATISH CHANDRA SHARMA, J.

1. Leave granted.

2. The present appeals challenge the judgment and order
dated 04.08.2023 passed by the High Court of Bombay in Writ
Petition 2340 of 2021 and other connected matters.

SLP (C) Nos. 20569-72/2023 and SLP(C) No. 25798/2024 Page 1 of 51

3. The present dispute raises important questions of law
relating to the interpretation and interplay between Section
144C and Section 153(3) of the Income Tax Act, 1961. More
specifically, what are the periods of limitations prescribed for
the revenue authorities to take action against an Assessee and
how the limitation periods and procedures prescribed in these
two sections coexist.

4. The facts necessary for the adjudication of the present
appeals are as follows:



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