THE COMMISSIONER OF INCOME TAX vs. PRIYANKA OVERSEAS P.LTD.

IN THE HIGH COURT OF DELHI AT NEW DELHI . 28.07.2009 6# Present: Ms. Sonia Mathur, Adv. for the appellant. . +ITA No. 723/2009 Learned counsel for the appellant argues that the reopening of the assessment under Section 147/143 (3) is wrongly quashed by the ITAT as time barred. In this behalf, it is submitted that the assessment year involved in the present case is 2000-01 and the period of 4 years would liable to expire on 31.03.2004 In the present case, even as per the Tribunal, the reasons for reopening the assessment are dated 23.04.2004 However, the Tribunal on the premise that 4 years expired on 31.03.2004, treated the assessment as time barred. Notice to the respondent, returnable on 6th January, 2010. . A.K. SIKRI, J. . . . . . VALMIKI J. MEHTA, J. July 28, 2009 pmc . .