147. Likewise, in CIT v. N. Jayaprakash

285 ITR 369High Court2006#3905 most cited

What is 147. Likewise, in CIT v. N. Jayaprakash authority for?

An assessee who successfully persuaded the assessing authority to withdraw a notice for reassessment because it was not in conformity with the law, cannot later argue that the notice was valid due to the omission of a time limit in a subsequent Finance Act. Proceedings initiated under the then-existing law by the Income-tax Officer are not invalidated without a specific provision to that effect.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2021.

Also referred to as

CIT v. N. Jayaprakash · 285 ITR 369 · Section 147 · Section 148 · reassessment notice · withdrawal of notice · time limit · Finance Act 1996 · validity of proceedings

Judgments citing 147. Likewise, in CIT v. N. Jayaprakash

M/S. GROWMORE RESEARCH & ASSETS MANAGEMENT LTD.,MUMBAI vs. DCIT CENT. CIR. - 4(3), MUMBAI

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 504/MUM/2019[1991-92]Status: DisposedITAT Mumbai30 Mar 2021AY 1991-92

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 1991-92 Dcit, M/S. Growmore Research Cent. Cir.-4(3) & Assets Management Central Range-4, Ltd., Room No.1921, 32, Madhuli Apartment, Vs. 19Th Floor, 3Rd Floor, Air India Bldg., Dr. Annie Besant Road, Nariman Point, Worli, Mumbai – 400 018 Mumbai - 400021 Pan: Aaacg4936C (Appellant) (Respondent) Assessment Year: 1991-92 M/S. Growmore Research Dcit & Assets Management Cent. Cir.-4(3), Ltd., Central Range-4, 32, Madhuli Apartment, Room No.1921, 3Rd Floor, Vs. 19Th Floor, Dr. Annie Besant Road, Air India Bldg., Worli, Mumbai – 400 018 Nariman Point, Pan: Aaacg4936C Mumbai - 400021

For Appellant: Shri Dharmesh Shah, A.RFor Respondent: Dr. P. Daniel, D.R
Section 147Section 14ASection 234Section 69

…/1996] dated 28.11.2003 4. CIT vs. Sudhir S. Mehta 9265 ITR 548] 5. CIT v. Ekbal and Co. [13 ITR 154(Bom)] 6. Deepika A. Mehta v. ACIT [57 TTJ 104(Mum)j 7. Chandi Ram v. ITO and Ors [225 ITR 611 (Raj.)] 8. N. Jayaprakash, Package India Tin Fabricators v. CIT [285 ITR 369 (Ker)] The Ld. A.R. prays before the Bench that in view of the facts of the case and the ratio laid down by the various judicial forums including Hon’ble Bombay High Court the notice issued under section 148 of the Act as well as consequent reassessment framed may kindly be quashed. 6.1 The Ld. A.R. further makes without prejudice argument that…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(3), CENTRAL RANGE-4, MUMBAI vs. M/S.GROWMORE RESEARCH & ASSET MANAGEMENT LIMITED, MUMBAI

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 1196/MUM/2019[1991-92]Status: DisposedITAT Mumbai30 Mar 2021AY 1991-92

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 1991-92 Dcit, M/S. Growmore Research Cent. Cir.-4(3) & Assets Management Central Range-4, Ltd., Room No.1921, 32, Madhuli Apartment, Vs. 19Th Floor, 3Rd Floor, Air India Bldg., Dr. Annie Besant Road, Nariman Point, Worli, Mumbai – 400 018 Mumbai - 400021 Pan: Aaacg4936C (Appellant) (Respondent) Assessment Year: 1991-92 M/S. Growmore Research Dcit & Assets Management Cent. Cir.-4(3), Ltd., Central Range-4, 32, Madhuli Apartment, Room No.1921, 3Rd Floor, Vs. 19Th Floor, Dr. Annie Besant Road, Air India Bldg., Worli, Mumbai – 400 018 Nariman Point, Pan: Aaacg4936C Mumbai - 400021

For Appellant: Shri Dharmesh Shah, A.RFor Respondent: Dr. P. Daniel, D.R
Section 147Section 14ASection 234Section 69

…/1996] dated 28.11.2003 4. CIT vs. Sudhir S. Mehta 9265 ITR 548] 5. CIT v. Ekbal and Co. [13 ITR 154(Bom)] 6. Deepika A. Mehta v. ACIT [57 TTJ 104(Mum)j 7. Chandi Ram v. ITO and Ors [225 ITR 611 (Raj.)] 8. N. Jayaprakash, Package India Tin Fabricators v. CIT [285 ITR 369 (Ker)] The Ld. A.R. prays before the Bench that in view of the facts of the case and the ratio laid down by the various judicial forums including Hon’ble Bombay High Court the notice issued under section 148 of the Act as well as consequent reassessment framed may kindly be quashed. 6.1 The Ld. A.R. further makes without prejudice argument that…

ITO 13(3)(3), MUMBAI vs. VULVAN TRADERS P. LTD, MUMBAI

ITA 4137/MUM/2015[2008-09]Status: DisposedITAT Mumbai30 Jan 2019AY 2008-09

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Years: 2008-09 Income Tax Officer-13(3)(3), M/S Vulvan Traders, 805, Room No.227,02Nd Floor, A Wingh, Corporate Avenue, बनाम/ Aayakar Bhavan, Sonawala Raod, Vs. M. K. Road, Goregaon East, Mumbai-400020 Mumbai-400063 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No.Aaacv1603K Assessment Years: 2008-09 M/S Vulvan Traders, 805, Income Tax Officer-13(3)(3), A Wingh, Corporate Room No.227,02Nd Floor, बनाम/ Avenue, Sonawala Raod, Aayakar Bhavan, Vs. Goregaon East, M. K. Road, Mumbai-400063 Mumbai-400020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No.Aaacv1603K

Section 143(1)Section 147Section 148

…n assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147 of the Act. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of spec…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…t make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time- limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of sp…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…t make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time- limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of sp…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…t make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time- limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of sp…

SOLO HARDWARE P. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

The appeals of the assessee are dismissed

ITA 1486/MUM/2017[2011-12]Status: DisposedITAT Mumbai24 Oct 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Ramit Kochar

Section 115JSection 139Section 142Section 142(1)Section 143Section 143(3)Section 147Section 148

…make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of spe…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1787/MUM/2018[2011-12]Status: DisposedITAT Mumbai11 Oct 2018AY 2011-12

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…a) P. Ltd., (2005) 279 ITR 372 (Ker), held that the entry would amount to an order under section 144. The under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1786/MUM/2018[2010-11]Status: DisposedITAT Mumbai11 Oct 2018AY 2010-11

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…a) P. Ltd., (2005) 279 ITR 372 (Ker), held that the entry would amount to an order under section 144. The under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1785/MUM/2018[2009-10]Status: DisposedITAT Mumbai11 Oct 2018AY 2009-10

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…a) P. Ltd., (2005) 279 ITR 372 (Ker), held that the entry would amount to an order under section 144. The under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

SHRI DINESHKUMAR C. DOSHI,MUMBAI vs. INCOME TAX OFFICER 19(1)(4), MUMBAI

The appeals of the assessee are dismissed

ITA 1730/MUM/2018[2011-12]Status: DisposedITAT Mumbai11 Oct 2018AY 2011-12

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…t make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10- 1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of s…

ITO 6(3)(2), MUMBAI vs. JAYDEEP PROFILES P.LTD, MUMBAI

ITA 3236/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

JAYDEEP PROFILES PVT. LTD.,MUMBAI vs. ITO WD 6 (3)(2), MUMBAI

ITA 2698/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

MOHD HASAN ABDUL GAFOOR MOMIN,THANE vs. ITO WD 1(2), KALYAN

The appeal of the assessee is partly allowed

ITA 3336/MUM/2017[2007-08]Status: DisposedITAT Mumbai18 Sept 2018AY 2007-08

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 Mohd. Hasan Abdul Gafoor Momin, Income Tax Officer, 430/2, Kotwal Shah Dargha Ward-1(2), बनाम/ Road, Bhiwandi, District- Thane, 1St Floor, Mohan Plaza, Vs. Maharashtra-421308 Wayale Nagar, Kalyan ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aekpm0354F

Section 143(3)Section 147Section 148Section 254

…make such an assessment recorded in the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

IDHASOFT LTD.,MUMBAI vs. DCIT - 15(2)(1), MUMBAI

ITA 5139/MUM/2016[2007-08]Status: DisposedITAT Mumbai13 Jul 2018AY 2007-08

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2007-08 M/S Idhasoft Ltd. Dcit-15(2)(1), 3, Narayan Building, Room No.357, 3Rd Floor बनाम/ 23 L. N. Road, Dadar East, Aayakar Bhavan, Vs. Mumbai-400014 M. K. Road, Mumbai-400020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aabci6090G Assessment Year: 2007-08 Dcit-15(2)(1), M/S Idhasoft Ltd. Room No.357, 3Rd Floor 3, Narayan Building, बनाम/ Aayakar Bhavan, 23 L. N. Road, Dadar East, Vs. M. K. Road, Mumbai-400014 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aabci6090G

Section 142(1)Section 143(3)Section 147Section 148Section 68

…the order sheet illegal and that would not bar further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 29 5139 & 5338/Mum/2016 Idhasoft Ltd. 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10- 1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of s…

ITO 19(2)(3), MUMBAI vs. MEENAKSHI N SHAH, MUMBAI

ITA 7082/MUM/2016[2007-08]Status: DisposedITAT Mumbai20 Jun 2018AY 2007-08

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2007-08 Dcit 5(2)(2) Meridian Chem Bond Mumbai Purchase Ltd., बनाम/ 903 Raheja Centre, Free Vs. Press Journal Marg, Nariman Point, Mumbai 400 021 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. Aaacr1789G

Section 68

…an Chem Bond P Ltd. & Meenakshi N Shah ITA No.7385 & 7082/Mum/2016 & C.O. No.86 & 85/Mum/2018 proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10- 1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of s…

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

ITA 3006/MUM/2016[2010-11]Status: DisposedITAT Mumbai16 May 2018AY 2010-11

Bench: Shri Joginder Singh & Shri G. Manjunatha

Section 143(2)Section 144Section 147Section 148Section 40A(3)

…further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. ITA Nos.2313 to 2315 and 3004 to 27 3006/Mum/2016 M/s Vipul Impex & Infrabuild Ltd. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

ITA 3005/MUM/2016[2008-09]Status: DisposedITAT Mumbai16 May 2018AY 2008-09

Bench: Shri Joginder Singh & Shri G. Manjunatha

Section 143(2)Section 144Section 147Section 148Section 40A(3)

…further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. ITA Nos.2313 to 2315 and 3004 to 27 3006/Mum/2016 M/s Vipul Impex & Infrabuild Ltd. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

ITA 3004/MUM/2016[2007-08]Status: DisposedITAT Mumbai16 May 2018AY 2007-08

Bench: Shri Joginder Singh & Shri G. Manjunatha

Section 143(2)Section 144Section 147Section 148Section 40A(3)

…further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. ITA Nos.2313 to 2315 and 3004 to 27 3006/Mum/2016 M/s Vipul Impex & Infrabuild Ltd. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

DCIT CIR. 4(3)(2), MUMBAI vs. VIPUL IMPEX & INFRABUILD LTD., MUMBAI

The appeals of the Revenue are allowed for statistical purposes

ITA 2315/MUM/2016[2010-11]Status: DisposedITAT Mumbai16 May 2018AY 2010-11

Bench: Shri Joginder Singh & Shri G. Manjunatha

Section 143(2)Section 144Section 147Section 148Section 40A(3)

…further proceedings under section 147. Thus, the assessment was held to be validly reopened under Explanation 2(c) to section 147. ITA Nos.2313 to 2315 and 3004 to 27 3006/Mum/2016 M/s Vipul Impex & Infrabuild Ltd. Likewise, in CIT v. N. Jayaprakash, (2006) 285 ITR 369 (Ker), where, the assessee could not, after having persuaded the assessing authority to withdraw the notice dated 1-10-1993, pointing out that it was not in conformity with law, be allowed to contend that the notice was valid due to the omission of the time-limit by the Finance (No.2) Act, 1996, with effect from 1-4-1989. In the absence of…

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147. Likewise, in CIT v. N. Jayaprakash (285 ITR 369) — Cited in 30 Judgments | BharatTax