Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2014 (7) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (7) TMI 14 - HC - Income TaxRevision u/s 263 - commencement of period of limitation from the date of original assessment or date of reassessment u/s 147 - revenue contended that AO failed to consider new ground during the course of reassessment proceedings which were not included in the notice u/s 148 and therefore the order is erroneous and prejudicial to revenue - Held that:- The Commissioner of Income Tax was aware that the period of limitation provided for in sub-section (2) of section 263 would commence from the date of original assessment which is on 22nd March, 2004 - The order of the Commissioner of Income Tax under section 263 of I.T. Act, is dated 30th March, 2009. It is in these circumstances, that we are of the opinion that the finding of fact recorded by the Tribunal on the point of the limitation, cannot be said to be vitiated by an error of law apparent on the face of the record nor it can be termed as perverse. – no substantial question of law arises for consideration - there is no question of explanation (3) being noticed by the Tribunal – Decided against revenue.
|