2014 (5) TMI 197

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..... beyond the period of 365 days even after insertion of third proviso to sub-section (2A) of Section 254 of the Act - as such, there is no pronouncement in Commissioner of Income Tax versus Ronuk industries Limited [2010 (11) TMI 461 - Bombay High Court] and a statutory authority, which has been granted statutory power, can exercise such power within the four corners of the statute granting such pow .....

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..... king note of the fact that as on 30th July, 2007, the third proviso to sub-section (2A) of Section 254 of the Income Tax Act, 1961 (hereinafter referred to as the Act ) was not in existence, which came to be inserted only with effect from 1st October, 2008. This aspect of the matter, the Tribunal failed to take note of and erroneously held as if it was held in Commissioner of Income Tax versus Ro .....

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