9911796707
TMI Blog2008 (9) TMI 88X X X X Extracts X X X X X X X X Extracts X X X X ..... t Panchnama, but the same has not been filed - no argument/contention of revenue before the Tribunal that Panchnama was containing a typographical / clerical error – assessment was rightly cancelled by ITAT on ground of limitation - 249/08 - - - Dated:- 30-9-2008 - BADAR DURREZ AHMED and RAJIV SHAKDHER, JJ. Ms. Prem Lata Bansal, Advocate for the Appellant. Dr. Rakesh Gupta, Ms. Poonam A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the month in which the last Panchnama was drawn i.e., two years from the 31.12.2000. The assessment should have been completed on or before 31.12.2002. The assessment order in this case was passed on 31.01.2003. In these circumstances, the Tribunal held the same to be barred by limitation. 4. The revenue had suggested that last Panchnama was not of 12.12.2000, but was of 03.01.2001. However, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Tribunal is perverse. We also note that there was no argument before the Tribunal with regard to the Panchnama dated 03.01.2001 containing a typographical / clerical error in the sense that although, it refers to the present assessee, but the name had been incorrectly shown as referring to a private limited company. 5. In these circumstances, we find that no substantial question of law aris ..... X X X X Extracts X X X X X X X X Extracts X X X X
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