On writ the court held that proceedings pending as of 1-6-2016, aimed at giving effect to orders under section 153(5) or implementing findings/directions under section 153(6), must be concluded by 31-3-2017 or within twelve months from end of month in which such orders were received, whichever is later. In view of above clarification it could not be said that proceedings pending to give effect to orders or findings/directions as of 31-3-2017, were saved under provisions of section 153. Circular 3/2017, dated 20-1-2017.. CIT v. Shelly Products (2003) 129 Taxman 171/ 261 ITR 367 (SC) (AY. 2007-08 to 2009-10)
United Spirits Ltd. v. ACIT (2024) 296 Taxman 141 (Karn)(HC)
S. 153 : Assessment-Reassessment-Limitation-Tribunal-Power-Limitation-Where Appellate Authority remands case for a determination on a selected issue or aspect of assessment, parties are fully aware of parameters within which fresh enquiry is circumscribed and limited-Rigours of limitation are totally removed-Tribunal had directed Assessing Officer to consider question of disallowance for bad debts/advances being written off-Tribunal’s order did not set aside or cancel subject assessment orders requiring a fresh assessment. [S. 153(2A), 153(6) 153(7) 253, 254(1)]