Direct reference to Supreme court u/s 257 in case of divergence of opinion amongst High court.

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..... e orders of the appellate Tribunal for filing reference application u/s.256(1) they should instruct the Departmental Representatives to request the Tribunal to make a direct reference to the supreme court u/s.257 if there are conflicting decisions of two or more High Courts on any particular question of law. Further even in a reference sought by the assessee the Departmental Representatives were a .....

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..... falling under clause b in such reassessment proceedings initiated beyond the period of four years under clause(a). According to the court a notice of reassessment cannot be issued after the period of 4 years in respect of items of income falling under clause(b) and the ITO cannot assume jurisdiction indirectly by issuing a notice purporting to be under clause(a). As against this view, Andhra Prade .....

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