(1.) THE controversy raised in this appeal is whether assessment in pursuance of direction of the Tribunal has been made within time -limit.
(2.) LEARNED counsel for the appellant submits that the assessment in consequence of the order of the Tribunal is not within time -limit.
(3.) THE finding of the Tribunal is in para 5 of its order and the relevant part where the admission of the learned counsel for the assessee has been recorded reads as under: