On writ the Court held that  the ITAT  has power to set aside Assessment Order and direct a de novo enquiry, in which case every aspect, computation and dimension is open for consideration. This partakes nature of an assessment which is akin to original assessment and, therefore, period of limitation applicable to original assessment must apply to fresh assessment. However, 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 and thus, rigours of limitation are totally removed. Tribunal had directed Assessing Officer to consider question of disallowance for bad debts/advances being written off, permitting assessee to produce further documents, and directing Assessing Officer to extend an opportunity of hearing to assessee and decide matter, Tribunal’s order did not set aside or cancel subject assessment orders requiring a fresh assessment. CIT v. Shelly Products (2003) 129 Taxman 171/ 261 ITR 367 (SC)  AY. 2007-08 to 2009-10)