M/S. Bhuwalka Steel Industries Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore
In the result, appeal by the assessee is allowed for statistical purposes
ITA 1599/BANG/2019[2015-16]Status: DisposedITAT Bangalore31 May 2023AY 2015-16
Bench: Shri George George K & Shri Laxmi Prasad Sahu
For Appellant: Shri. T. Srinivasa, CAFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92BSection 92C
…h the rule has been framed in that case also the pending proceeding will not be affected by omission of the rule. A further reliance was also placed upon the judgment of the Apex Court in the case of General Finance Co. v. Assistant Commissioner of Income-tax 257 ITR 38 ($.). in which the Apex Court has held that the principle underlying section 6 as saving the right to initiate proceedings for liabilities incurred during the currency of the Act will not apply to omission of a provision in an Act but only to repeal, Omission being different from repeal as held in the aforesaid decisions. Reliance was also placed…