In Brief
In this appeal, the Supreme Court examined whether substantial questions of law raised in a memo of appeal before the High Court under Section 260A of the Income Tax Act, 1961 were considered in the High Court's order. Finding that the issue concerning the powers of Commissioner (Appeals) raised under Rule 46A appeared not to have been addressed, the Court permitted the appellant to file a review application before the High Court. The Court held that such review application shall be considered without raising the question of limitation, and all remaining questions were left open for future raising if needed. The appeal was disposed accordingly.
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