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| The Tax Publishers2020 TaxPub(DT) 4433 (Mad-HC) : (2021) 430 ITR 0515 : (2021) 277 TAXMAN 0234 INCOME TAX ACT, 1961
Section 147
Where notice under section 148 was issued much beyond the period of four years from the end of relevant assessment year (1997-98), therefore, Tribunal was justified in annulling the re-assessment order of relevant assessment year on ground of same being barred by limitation as per proviso to section 147.
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Reassessment - Validity - Notice under section 148 issued much beyond the period of four years from end of relevant assessment year (1997-98) -
Revenue challenged order of Tribunal holding that re-opening of assessment was bad in law as it was barred by limitation period. Held: In case of assessee, notice under section 148 was issued much beyond the period of four years from the end of relevant assessment year (1997-98). Therefore, Tribunal was justified in annulling the re-assessment order of relevant assessment year on ground of same being barred by limitation as per proviso to section 147.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 1997-98
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