Mere filing of an appeal before the High Court or the Supreme Court would not preclude the competent authorities from exercising their powers, which are otherwise conferred under the provisions of the Act. Unless any interim order or otherwise is communicated to the authorities, they are bound to proceed under the provisions of the Act, in the manner known to law. According to the judgment of the Constitution Bench of the Supreme Court of India, in the case of National Insurance Co. Ltd. v. Pranay Sethi [2017] (2) TN MAC 609 (SC), the mere pronouncement of the order would not be sufficient. The order must be signed, sealed, dated and communicated to the parties, enabling them to understand the reasons and the spirit of the order. The order which is signed by the authority and appropriately sealed by the court concerned, which is communicated to the party alone must be the date on which the period of limitation commences and not from the date on which the parties have the knowledge by themselves or through their counsel or otherwise. (AY. 2005-06, 2006-07)
Pentamedia Graphics Ltd. v. ACIT (2021)438 ITR 108 (Mad.)(HC)
S. 153 : Assessment-Reassessment-Limitation-Limitation would commence from date of passing of order by competent Authority or Court properly signed and sealed by court and communicated to parties-Mere filing of appeal will not preclude competent Authority from proceeding under law. [S.143(3)]