TMI Blog2022 (7) TMI 1395X X X X Extracts X X X X X X X X Extracts X X X X ..... ch extended limitation for reopening assessment to sixteen years could not be resorted for reopening proceedings concluded before amendment came into effect. Admittedly the amendment came into effect on 1st July, 2012 and the notice under Section 148 was issued on 19th August, 2013. The Tribunal after taking note of the decision in Brahm Datt [supra] took into consideration of the facts of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... period of limitation for preferring appeals under various statutes. For such reason the application is allowed and the delay is condoned. ITAT/74/2022 This appeal filed by the revenue under Section 260A of the Income Tax Act, 1961 (the Act for brevity) is directed against the order dated 10.1.2020 passed by the Income Tax Appellate Tribunal C Bench, Kolkata (Tribunal) in ITA No.37 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vision of section 149[1][c] applicable, to those proceedings which had become barred by limitation on 01.07.2012? We have heard Mr. Tilak Mitra, learned standing Counsel for the appellant/revenue and Mr. Pratyush Jhunjhunwala, learned Advocate appearing for the respondent. The short question falls for consideration is whether the proceeding initiated by the assessing officer under section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot be resorted for reopening proceedings concluded before amendment came into effect. Admittedly the amendment came into effect on 1st July, 2012 and the notice under Section 148 was issued on 19th August, 2013. The decision in Brahm Datt (supra) as well as other decisions were noted in the case of SMT. N. ILLAMATHY VS. INCOME TAX OFFICER, WARD-11(2);[2020] 120 taxmann.com 313 (Madras) . At this j ..... X X X X Extracts X X X X X X X X Extracts X X X X
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