TMI Blog2015 (8) TMI 983X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act would be six years, which would be expiring on 31.3.2004 and thus reopening notice issued after 31.3.2004 would be barred by limitation, as the extended time limit would not be available for the present case because the order of Tribunal passed on 7.4.2006 was itself passed beyond the said period. Thus reopening on the basis of an order passed by the Tribunal beyond the period of limi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he sum of ₹ 4,97,046/- represents unexplained investments in the construction of the building for the A.Y.1997-98 on the facts and circumstance of the case? (iii) Whether the Tribunal was justified in law in appreciating the levy of interest u/s 234A, B, D of the Act on the facts and circumstances of the case? 2. Brief facts of the case are that for the assessment year 1997-98, appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e expiring on 31.3.2004 and thus reopening notice issued after 31.3.2004 would be barred by limitation, as the extended time limit would not be available for the present case because the order of Tribunal passed on 7.4.2006 was itself passed beyond the said period. In support of this submission, Sri A Shankar, learned counsel for the appellant relies on the decision of the Apex dated 20th Septembe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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