- (1.) Learned counsel has received instructions. His instructions are taken on record. It becomes apparent that the record is not available with him at the present moment. Hence, the case to proceed on the available record.
(2.) Heard Sri S.D.Singh, learned Senior Counsel, assisted by Sri Tanmay Sadh for the assessee and Sri Manish Goyal, learned counsel for the department.
(3.) This is an Income Tax appeal filed under Section 260-A of the Income Tax Act, 1961 against the order of the Tribunal dated 09.03.2007, for the block period ending on 21.08.2000. The questions of law sought to be answered are as under:- "(1) Whether the Tribunal was right in law in holding that the Block assessment order dated 29.08.2002 u/s 158BC was barred by limitation without appreciating the facts that the action u/s 132A was executed in respect of authorization for requisition u/s 132A of the I.T. Act, 1961 dated 15.06.1995 and therefore the section 158BE (1) (b) is applicable in this case and not in section 158BE (1) (a). Accordingly the limitation was two years from the end of the month in which the authorization was executed and not one year. (2) Whether the Tribunal has erred in law and on facts in holding that the authorization dated 15.06.1999 was in continuation of authorization for requisition u/s 132A dated 11.9.1995 when there is no provision in the I.T. Act, 1961 allowing any authorization for requisition u/s 132A being drawn in continuation of earlier authorization u/s 132A.";