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2013 (10) TMI 108 - HC - Income TaxExtension of attachment u/s 281B(2) of the Income Tax Act – petition for recall of order where request for extension was rejected - Held that:- Third proviso to Section 281B(2) of the Act provides is for exclusion of the period of two years provided in first proviso, during which the proceedings of assessment are stayed by any Court. This is not the issue in the present matter at all – In the present case, after extension there was no further extension – High court has never precluded the applicant-Department from extending the attachment if it was otherwise open to do so in law. The extension of attachment and extension of uppermost time limit for attachment are two vastly different aspects - Request for recall is rejected – Decided against the Revenue.
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