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2011 (5) TMI 667 - AT - Income TaxAssessment - barred by limitation, invalid and inoperative in law - Whether Proceedings u/s 144 of the I.T. Act 61 and that u/s 147 of the Act are different proceedings as Sec 153 of the I.T Act 1961 provides different time-limit for each of the proceedings and therefore an order u/s 144 of the Act 1961 in a proceedings u/s 147 of the I.T. Act 1961 is misleading, unworkable and inoperative in law - ground rejected - whether disallowances and additions were fanciful surmise and should have deleted them – whether CIT(A) was not justified in holding that the proceedings u/s 147 of the Act was valid even in absence of fresh information – whether CIT(A) wrongly hold that the assessee was liable u/s 194C of the Act to deduct tax at source from Freight charges though the Lorries hired by the assessee carried goods only – whether CIT(A) should have that the assessee was not liable to pay advance tax on additions & disallowances u/s 208 of the I.T. Act 1961 but on current income only and consequently was not liable to pay interest u/s 234B of the I.T. Act 1961
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