New Higher Secondary School, Trivandrum vs. DCIT, Trivandrum
In the result, the appeals by the assessee are dismissed
ITA 54/COCH/2023[2015-16 (Qurt-3)]Status: DisposedITAT Cochin28 Aug 2023
Bench: Shri Sanjay Arora & Shri Manomohan Das
For Appellant: Shri Sreeram Sekar, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200ASection 234E
…splaced. None of the cited decisions by the Hon'ble Apex Court, clarifying the law on limitation, stands addressed by the assessee, much less met, even before us. In Municipal Corporation of Delhi vs. International Security and Intelligence Agency Ltd. [2004] 3 SCC 250, it is clarified that the law of limitation operates with all its rigour, and equitable considerations are out of place in applying the same. In P.K. Ramachandran vs. State of Kerala[1997] 7 SCC 556, the Apex Court again clarifies that the courts have no power to extend the period of limitation on equitable grounds, even as it may harshly affect a…