Section 153(2): Period of 60 days to be counted from whether date of vacation of stay or date of receipt of order

Saheb Ram Om Prakash Marketing (P) Ltd. Vs. CIT & Ors. (Delhi High Court) The Court is also unable to accept the submission that the 60 day period in terms of the first proviso to Explanation 1 to section 153 of the Act should begin to run from the date on which the Revenue received a copy of the order of vacation of stay. Such an interpretation is not supported by the plain language of the proviso to Explanation 1. In fact, Circular No. 621, date 19-12-1991 issued by the Central Board of Direct Taxes, while explaining the reasons for introduction of the proviso under Explanation 1, ackno...