Allowing the appeal the Court held that when the order passed by the Tribunal had been set aside in its entirety by this court, it was open to the assessee to raise the plea of limitation. Since the Tribunal had not adjudicated the issue with regard to limitation, the order passed by the Tribunal in so far as it pertained to the finding with regard to the issue of limitation was quashed and the Tribunal was directed to decide the issue of limitation with regard to the order of assessment passed by the Assessing Officer for the block assessment years 1986-87 to 1996-97. It would be open to the parties to raise all contentions before the Tribunal on this issue. (AY. 1986-87 to 1996-97)