Applicability of time-limit U/s. 153(2A) when ‘assessment’ is set aside and an ‘assessment order’ being set aside

Nokia India (P) Ltd. Vs Dy. CIT (Delhi High Court)  Having perused the impugned order of the ITAT carefully and the operative portions qua which the assessment order was set aside and the matter remanded to the assessing officer, the Court is unable to agree with the contention of learned ASG that the aforementioned order of the ITAT did not constitute a complete setting aside of the assessment with directions to the assessing officer to pass a fresh order. The Court does not agree with the submission of the learned ASG that the assessing officer was ‘chained’ by the ITAT’s directions ...