TMI Blog2014 (1) TMI 448X X X X Extracts X X X X X X X X Extracts X X X X ..... For the Appellant : Mr. H.M. Bhatia, Adv For the Respondent : Mr. C.S. Agarwal, Sr. Adv assisted by Mr. P.R. Mullick, Adv JUDGEMENT PER : Barin Ghosh, CJ The completed assessment was purported to be opened in exercise of power under Section 147 of the Income Tax Act in view of a subsequent pronouncement by a Court. In McDermott International Inc Vs. Additional Commissioner of Inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t Appeal, there has been 705 days delay. In the grounds of Appeal, it has not been stated, why this Court should be persuaded to take a different view than what has been expressed by this Court in the judgment referred to above; while in the Application for condondation of delay, no cogent reason for delay has been furnished. 2. In the circumstances, we refuse to condone the delay. Consequentia ..... X X X X Extracts X X X X X X X X Extracts X X X X
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