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2011 (8) TMI 169 - HC - Income TaxReview of earlier order - Search and seizure - Block assessment addition of bogus purchase - Time limitation - the words "expressly excluded" would mean that there must be an express reference made in the special or local law to the specific provisions of the Limitation Act of which the operation is to be excluded - even in a case where the special law does not exclude the provisions of sections 4 to 24 of the Limitation Act by an express reference, it would nonetheless be open to the court to examine whether and to what extent, the nature of those provisions or the nature of the subject-matter and scheme of the special law exclude their operation - Held that: - We, consequently, dispose of this application by clarifying our above observation that we never intended to direct the Assessing Officer to bring those transactions within regular assessment after the expiry of the period of limitation prescribed under the Income-tax Act by taking aid of section 14 of the Limitation Act which is not even applicable.
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