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TMI Blog2008 (1) TMI 378X X X X Extracts X X X X X X X X Extracts X X X X ..... ptember 22, 2006, passed by the Income-tax Appellate Tribunal, Delhi Bench "E" in I. T. A. No. 4618/ Del/2003 relevant to the assessment year 1996-97. M/s. Marubeni Corporation had filed a return purportedly as the agent of the assessee. 2. The return was filed on June 24, 1996. A notice was issued to the assessee under section 148 of the Income-tax Act, 1961 (for short "the Act") on January 14, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er 1, 2007. 4. The Tribunal, by the order under challenge, accepted the additional ground raised by the assessee and came to the conclusion that the notice issued to the assessee under section 148 of the Act was barred by time. 5. Learned counsel for the Revenue has drawn our attention to section 163 of the Act to contend that no order was passed to the effect that M/s. Marubeni Corporation was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R 347 (Mad). On a reading of the decision, it appears to us that the High Court has not taken a conclusive decision on the question whether an order is required to be passed treating a person as an agent of the assessee. But it appears that only an adverse order, which is appealable, is required to be made in writing so that the right of the assessee or his agent is not frustrated. In other words, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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