COMMISSIONER OF INCOME TAX-I Vs. SANGHI BROS.

JUDGEMENT

(1.) THE present appeal preferred under Section 260A of the Income -tax Act, 1961 was admitted on following two substantial questions of law:

(2.) WHETHER in the facts and in the circumstances of case and in law the Tribunal is justified in holding that the assessment has illegally been made. Thus he same is annulled ?

(3.) AS far as facts are concerned, as it perceived, there is no dispute, with regard to the dates. The question that has been raised, by the revenue fundamentally pertains to the stand that the prescription of limitation under Section 16(1) should not be made applicable when assessment is reopened under Section 17 of the Act.