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2004 (11) TMI 98 - HC - Income TaxChallenge in this writ petition is to the validity of notice u/s 148 by which proceedings u/s 147 have been initiated to reassess the income for the assessment year 1997-98 which is alleged to have escaped assessment. - there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for its assessment for the assessment year 1997-98. Accordingly, the initiation of proceedings under section 147 after the expiry of four years from the end of the assessment year is wholly without jurisdiction. - Accordingly, we allow this writ petition and quash the impugned notice under section 148
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