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2009 (7) TMI 54 - PUNJAB AND HARYANA HIGH COURTInitiation of proceedings u/s 147 – validity of proceedings – ignorance of explanation 2(b) of section 147 - Even if it is assumed that proceedings could not be initiated under Section 147 in respect of pending assessment, there being no bar in the present case to proceed under Section 143(2), proceedings were valid - It is true that this aspect was not raised by the revenue before the CIT(A) or before the Tribunal but this being purely legal point arising out of the admitted facts, HC allow this point to be raised at this stage – decision of ITAT reversed
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