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2021 (2) TMI 647 - HC - Income TaxValidity of reopening of assessment - Notice u/s 143(2) as barred by limitation - HELD THAT:- In the facts and circumstances of the case, it is not necessary for us to deal with the substantial questions of law framed in this appeal. The impugned order passed by the Tribunal dated 27.05.2016, is hereby quashed and the matter is remitted to the Tribunal to adjudicate the issue whether the notice issued under Section 143(2) of the Act dated 28.02.2013, to the assessee is barred by limitation and is contrary to provisions of the Act. Needless to state that the Tribunal itself shall decide the issue within a period of two months from the date of receipt of certified copy of the order passed today. The parties shall be at liberty to raise all legal contentions with regard to the aforesaid issue.
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