9911796707
TMI Blog2010 (1) TMI 114X X X X Extracts X X X X X X X X Extracts X X X X ..... 010 @ S.L.P. (C) No.4774/2009, Civil Appeal No.755/2010 @ S.L.P. (C) No.7491/2009, Civil Appeal No.756/2010 @ S.L.P. (C) No.8162/2009, Civil Appeal No.757/2010 @ S.L.P. (C) No.8177/2009, Civil Appeal No.758/2010 @ S.L.P. (C) No.8146/2009, Civil Appeal No.759/2010 @ S.L.P. (C) No.8661/2009, Civil Appeal No.760/2010 @ S.L.P. (C) No.7745/2009, Civil Appeal No.761/2010 @ S.L.P. (C) No.6415/2009 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rred by time having been passed beyond a reasonable period." Having heard learned counsel on both sides, we are of the view that, on the facts and circumstances of these cases, the question on the point of limitation formulated by the Income Tax Appellate Tribunal in the present cases need not be gone into for the simple reason that, at the relevant time, there was a debate on the question as to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ake not to claim refund for the amounts paid. Before concluding, we may also state that, in Eli Lilly & Co. (India) Pvt. Ltd. (supra) vide Paragraph 21, this Court has clarified that the law laid down in the said case was only applicable to the provisions of Section 192 of the Income Tax Act, 1961. Leaving the question of law open on limitation, these civil appeals filed by the Department are dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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