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2016 (2) TMI 1168 - ITAT KOLKATAReopening of assessment - notices u/s 148 beyond period of limitation - Held that:- Notices issued u/s. 148 was dated 30.03.2005 and 31.03.2006 for AYs 1998-99 and 1999-2000 respectively but, these were issued, as admitted by Ld. Sr. DR, after 31.03.2005 and 31.03.2006. And records clearly shows that both the notices were handed over to Postal Authorities on 05.04.2005 and 07.04.2006 for AYs 1998-1999 and 1999-2000 respectively. Notices have been dispatched/left the control of the officer only after the end of the financial year and the same was served only on 16.05.2005 for AY 1998-99 and 05.06.2006 for AY 1999-2000 respectively. It means that the same have clearly been issued beyond the prescribed period of limitation - Decided in favour of assessee.
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