Dismissing the appeal of the Revenue the division bench held that notice by Dispute Resolution Panel four years after direction by Tribunal is barred by limitation by application of provisions of section 153(2A) of the Act. High Court has the power to quash show-cause notice.(AY.2009-10, 2010-11)
CIT. v. Roca Bathroom Products P. Ltd (2022) 445 ITR 537/ 216 DTR 320/ 328 CTR 14 (Mad.)(HC) Dy. CIT v. Freight Systems (India) P. Ltd. (2022) 445 ITR 537/ 216 DTR 323 / 328 CTR 14 / 445 ITR 537 (Mad.)(HC) Editorial : Decisions of single judge affirmed, CIT. v. Roca Bathroom Products P. Ltd (2021) 432 ITR 192 (Mad)(HC)/ Dy. CIT v. Freight Systems (India) P. Ltd. (2021) 18 ITR-OL 468 (Mad)(HC)/SLP is granted to the Revenue , CIT. v. Roca Bathroom Products P. Ltd (2023) 291 Taxman 529 (SC)
S. 144C : Reference to dispute resolution panel-Limitation-Notice by Dispute Resolution Panel four years after direction by Tribunal-Barred by limitation-High Court has power to quash show-cause notice-Decisions of single judge affirmed. [S. 92C, 92CA, 144C(13), 153, 254 (1), Art. 226]