1999 (2) TMI 631

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..... .. In an appeal preferred by the assessee-department was earlier having right to file cross-objections within thirty days and now by virtue of amendment by Act 15 of 1991 it is stated that an indefinite time has been permitted by the Legislature for filing the memorandum of cross-objections. It is pointed out that provisions under C.P.C., Income-tax and other Acts have provided the limitation of 3 .....

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..... pellate Tribunal as if it were an appeal presented within the time specified in sub-section (1). 3.. Arguments of both learned counsel for parties have been heard. 4.. At the outset, it may be observed that provisions of section 22(2A) are not indefinite in the sense that the memorandum of cross-objections could be filed before finally hearing of the appeal. Once the appeal is finally heard, .....

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