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2013 (10) TMI 288 - HC - Income TaxLimitation – Notice for penalty u/s 271(1)(c) of the Income Tax Act – Held that:- Notice under Section 271(1)(c) of the Act was not served on the assessee on 17.03.1988 as claimed by the department found the assessment to be barred by limitation under Section 153(1)(a) of the Act - In view of the reasons recorded by revenue for reaching the conclusion that the notice under Section 271(1)(c) of the Act was handed over to the counsel on 13.03.1989, and by then, the time available for completion of assessment was already over on 31.03.1988 and that the department was not entitled for extended period of limitation under Section 153(1)(b) of the Act - Counsel for the appellant has failed to point out any perversity either in the findings recorded by the learned Tribunal or from the original record, which was summoned by this Court – Decided against the Revenue.
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