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2010 (4) TMI 45 - HC - Income TaxPeriod of limitation – proceeding u/s 201 and 201(1) were were initiated after the period of four years from end of the Financial Year in question had elapsed. - Tribunal, following the decision of this Court in the case of CIT Vs. NHK Japan Broadcasting Corporation (Delhi): [2008 -TMI - 30950 - DELHI HIGH COURT] agreed with the contention of the Assessee and held the proceedings to be barred by time. Consequently the cross objections were allowed and the Revenue’s appeal was dismissed. – held that - it is clear that the proceedings under Section 201/ 201(A) of the Income Tax Act, 1961 can be initiated only within three years from the end of the Assessment Year or within four years from the end of the relevant Financial Year. - Tribunal has correctly concluded that the proceedings were beyond time. – Decided in favor of assessee
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