PCIT v. CFL Capital Financial Services Ltd. (2024)465 ITR 17 /165 taxmann.com 111/ 300 Taxman 265 (SC) Editorial : PCIT v. CFL Capital Financial Services Ltd. (2024)465 ITR 15/165 taxmann.com 110 (Cal)(HC)

S. 153 : Assessment-Limitation-Remand by Tribunal-Remand on limited issue-Order of Tribunal is affirmed by High Court-SLP of Revenue is dismissed on account of delay [S. 153(3)(ii), Art. 136]

On appeal by the Department against an order holding the assessment made on the assessee barred by limitation, contending that only the issue relating to disputed purchase having been restored by the Tribunal, and not the entire assessment, the provisions of section 153(3)(ii) of the Income-tax Act, 1961 where no time limit is prescribed would be applicable, the High Court dismissed the Department’s appeal holding that as the Commissioner (Appeals) as well as the Tribunal had taken note of the factual position and held the assessment to be barred by time, no substantial questions of law arose. SLP of Revenue is dismissed on account of delay.    (AY.1995-96)