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2002 (10) TMI 74 - HC - Income TaxThis petition by an assessee is directed against notices issued under section 147 read with section 148 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act"). They have been impugned principally on the ground that they suffer from serious legal infirmity since they were issued after the expiry of four years from the end of the relevant assessment years, even in the absence of the condition or conditions as envisaged by a proviso to section 147 - Learned counsel for the respondents could not satisfy that there was any failure on the part of the assessee as envisaged by the proviso to section 147 or in any manner by suppression or omission, he took advantage and escaped the assessment. - In the result, we allow the petition and quash the impugned notices
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