TMI Blog2010 (4) TMI 45X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 Yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n as much as the proceedings under Sections 201 and 201(A) were initiated after the period of four years from end of the Financial Year in question had elapsed. 3. Tribunal, following the decision of this Court in the case of CIT Vs. NHK Japan Broadcasting Corporation (Delhi): [2008] 305 ITR 137 (Delhi) agreed with the contention of the Assessee and held the proceedings to be barred by time. C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is two year from the end of the assessment year in which the income was first assessable. It is well known that the assessment year follows the previous year and, therefore, the time limit would be three years from the end of the financial years. This seems to be a reasonable period as accepted under section 153 of the Act, though for completion of assessment proceedings. The provisions of reasse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not less. Nevertheless, the Tribunal has given a greater period for commencement or initiation of proceedings. 21. We are not inclined to disturb the time limit of four years prescribed by the Tribunal and are of the view that in terms of the decision of the Supreme Court in Bhatinda District Co-op. Milk Producers Union Ltd. [2007] 9RC 637; 11SCC 363 action must be initiated by the competent au ..... X X X X Extracts X X X X X X X X Extracts X X X X
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