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2003 (6) TMI 24 - UTTARANCHAL HIGH COURT
Notice issued under section 147 read with section 148 - challenge to the notices is mainly on the ground that these have been issued after the expiry of four years from the end of the relevant assessment year even though the conditions as contemplated under section 147 of the Act were not satisfied. - the impugned notices dated May 29, 2001, issued under section 147 read with section 148 of the Act are without jurisdiction as the conditions precedent to reopen the assessment in terms of the proviso to section 147 are totally non-existent and, therefore, we allow the petition and quash the impugned notices.