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2003 (6) TMI 20 - HC - Income TaxNon-resident - In the writ petition the petitioners have challenged two notices. One dated passed by the Deputy Commissioner of Income-tax. treating CESC Limited as "representative assessee"/"agent" of the non-resident assessee, u/s 163 of the Income-tax Act, 1961. The other notice is dated March 20, 2001, passed by the same officer under section 148 seeking to reopen the assessment - In the result, this appeal succeeds in part only with regard to the notice under section 148 relating to reopening of the assessment under section 147 on the ground that this notice was issued on March 20, 2001, when the return submitted by the principal was pending and the assessment whereof was not completed till March 30, 2001. The notice, dated March 20, 2001, issued under section 148 impugned in the writ petition is, therefore, hereby quashed
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