9911796707
TMI Blog2024 (8) TMI 568X X X X Extracts X X X X X X X X Extracts X X X X ..... sment, re-assessment and re-computation apply to the proceedings u/s 144C which provide for cases where a reference may be made to the dispute resolution panel? - HELD THAT:- A decision is rendered by a co-ordinate Bench of this Court in Shelf Drilling Ron Tappmeyer Limited [ 2023 (8) TMI 460 - BOMBAY HIGH COURT] wherein a view is taken that the limitation as prescribed where Section 153 applies t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also placed on record. It is on such complexion, the proceedings were argued before us. Having heard learned Counsel for the parties, we reserve appropriate orders to be passed on the present proceedings. - G. S. KULKARNI SOMASEKHAR SUNDARESAN, JJ. For the Petitioner : Mr. Jehangir Mistri, Senior Advocate a/w. Rubal Bansal, Anuj Jhaveri, Prakhar Pandey a/w. Mihir Modi i/b. Anuj Jhaveri. For the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reference may be made to the dispute resolution panel. 3. On such provisions a decision is rendered by a co-ordinate Bench of this Court in Shelf Drilling Ron Tappmeyer Limited Vs. Assistant Commissioner of Income Tax Ors. (2023) 457 ITR 161 (Bom), wherein a view is taken that the limitation as prescribed where Section 153 applies to the proceedings under Section 144C. Also there is one more deci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... espective senior counsel for the parties, we observe that the impugned judgment shall not be cited as a precedent in any other subsequent matter until further orders. We also clarify that the operative portion of the judgment shall apply only insofar as the respondents herein are in question. (emphasis supplied) 5. On behalf of the Revenue, Mr. Venkataraman, the learned ASG has made elaborate subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Drilling (supra) as arising against the orders passed by this Court. 6. It is informed that the proceedings not only in Shelf Drilling (supra), but in several other cases arising from orders passed by the different High Courts on the same issue, are pending consideration before the Supreme Court. The orders passed by the Supreme Court issuing notice in such proceedings, are also placed on record ..... X X X X Extracts X X X X X X X X Extracts X X X X
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