9911796707
TMI Blog1990 (11) TMI 391X X X X Extracts X X X X X X X X Extracts X X X X ..... es Tax Appeal No. 243/1985/ST/Pali. In this case the only point urged by the learned counsel is that as the reassessment had already been made in pursuance of the remand order on August 5, 1986, which was within two years of the receipt of communication, the Tribunal was wrong in holding that: "It is clear from this notice that the extension was not granted till August 16, 1986. It has been he ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e completed within one year from the date of such commencement or within two years from the date of communication of such order to the assessing authority, whichever is later." Counsel's submission was that when the reassessment had been made the appeal pending before the Tribunal had become infructuous and the same should have been dismissed on that ground. To the dismissal of the appeals pendi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the assessing authority on August 7, 1984. If two years are calculated on the basis of the amended section 1013, quoted above, reassessment made on August 5, 1986, would be well within time. However, as stated above, I am not called upon to go into this controversy on merits. What is required only is to clear off the parties of the effect of the observation of the Tribunal's judgment extracte ..... X X X X Extracts X X X X X X X X Extracts X X X X
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