RITZ LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) BY this reference under S. 256(1) of the IT Act, 1961 made at the instance of the assessee, the Tribunal, Bombay has referred the following question of law to this Court for opinion :

(2.) THE controversy involved in the above question is in a very narrow compass. It pertains to the period of limitation applicable to or reassessments made under S. 147 of the IT Act, 1961. We shall, therefore, narrate only those facts which are relevant for the purpose of determining the above controversy.

(3.) THESE orders of reassessment were confirmed on appeal both by the CIT(A) and the Tribunal. The assessee applied for reference. On the application of the assessee, the Tribunal has referred the above question to this Court for opinion.