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2006 (3) TMI 105 - HC - Income TaxReassessment under section 147 - limitation - assessee-company had fully and truly disclosed all material facts necessary for computing the depreciation allowance in the course of the original assessments completed under section 143(3) itself, the period of limitation applicable to the reopening for these two years would be a period of four years prescribed in the proviso to section 147 of the Income-tax Act, 1961. For the said two years, notice under section 148 had been issued after the expiry of four years from the end of the assessment years, 1992-93 and 1993-94. - Therefore, any notice issued after the expiry of four years from the end of the relevant assessment year, is illegal and is without jurisdiction.
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