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2016 (9) TMI 512 - HC - Income TaxReopening of assessment - time limit to raise objections - Held that:- Admittedly, the objection was not raised by the appellants within 30 days even from the date of issuance of notice under Section 148. The objection was raised by a letter dated 29th April, 2015 and the notices under Section 148 were received on 27th March, 2015. It is not also possible to contend that the period of limitation shall commence only from the date of issuance of the notice under Section 148. Notice under Section 148 was issued because prior thereto search and seizure was conducted and thereafter survey was conducted presumably leading to incriminating discovery. Thereafter documents were impounded and it is on the basis of these steps that the notice under Section 148 was issued. Each one of these steps was taken subsequent to 15th November, 2014 but the writ petitioner did not raise any objection. The assessee had questioned the territorial jurisdiction of the assessing officer and the assessing officer held that the assessee had lost the right to raise the objection by efflux of time. We, as such, find no substance in the case of the appellant.
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