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“within four years”

ReassessmentSection 147Section 147391 judgments

The decision most relied on for within four years is (P.) Ltd. v. ITO (221 ITR 538), cited in 125 judgments on BharatTax.

Leading authorities on within four years

(P.) Ltd. v. ITO
221 ITR 538 · 1996 · Supreme Court
125
citing judgments

The sanction of a specified authority under Section 151 is a mandatory procedural check before issuing a notice under Section 148. This procedural safeguard aims to prevent mechanical reopening of assessments and harassment of the assessee.

CIT v. NHK Japan Broadcasting Corporation
305 ITR 137 · 2008 · High Court
96
citing judgments

When no specific statutory period of limitation exists, proceedings under Section 201(1) and 201(1A) of the Income-tax Act, particularly for payments to non-residents, must be initiated within a reasonable period of four years. This limitation also applies to consequential penalty proceedings under Section 271C.

Dass Khanna v. ITO
460 ITR 546 · 2024 · High Court
41
citing judgments

The authority required to grant prior approval under Section 151 of the Income-tax Act for reassessment proceedings varies based on the applicable time limit for reassessment, as limitation is inextricably intertwined with the rank of the specified approving authority.

Venus Industrial Corporation v. Asst. CIT
236 ITR 742 · 1999 · High Court
32
citing judgments

Reopening an assessment within four years to re-examine a deduction under Section 80HHC, which was wrongly allowed in the original assessment, is valid. This is illustrated by cases where reassessment was held valid for re-examining deductions based on how excise duty was treated in the balance sheet.

340 ITR 299 (Bom.) (v) Desai Bros. Ltd. v. DCIT
267 ITR 161 · 2004 · High Court
30
citing judgments

The first proviso to section 147 of the Income Tax Act applies when an assessment is re-opened within four years from the end of the assessment year. If the assessment year is within four years, the conditions of the proviso are met.

232 Taxman 414 (Del. HC) 4. Yum Restaurants Asia Pte Ltd. v. DDIT
397 ITR 639 · 2017 · High Court
26
citing judgments

The approval for reopening of assessment must be obtained from the prescribed authority, which depends on whether the assessment is being reopened within four years or beyond four years from the end of the relevant assessment year.

236 ITR 832 (Guj) (para 21) Snowcem India Ltd. v. Deputy CIT
313 ITR 170 · 2009 · High Court
21
citing judgments

Reopening assessment proceedings under Section 147 is permissible within four years, even if full and true particulars were provided during the original assessment, provided the Assessing Officer forms a prima facie opinion of underassessment or escapement of income.

CIT v. Aquatic Remedies
406 ITR 545 · 2018 · High Court
21
citing judgments

Sanction for reopening an assessment under Section 151 requires approval from the specified authority, and approval from a superior but different authority is invalid. Even if the reopening is within four years, the correct authority must grant approval.

Judgments citing within four years

The ACIT, Central Circle-1, Bhopal vs. DB Power Ltd, Bhopal

Appeal is dismissed

ITA 73/IND/2023[2015-16]Status: DisposedITAT Indore24 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151Section 56(2)(viib)Section 69C

73/Ind/2023- A.Y. 2015-16 Commissioner or Commissioner for issuance of notice after expiry of four years, section 151(2) permits issuance of notice within four years after obtaining approval from much lower-level authority, namely Joint Commissioner. When the law provides a clear-cut mechanism, the statutory function ... done at all; there cannot be any other option. Ld. AR submitted that if the AO is allowed to obtain approval within four years from lower-authority in terms of section 151(2), just keep such approval in file and subsequently issue notice after four years, it would

DB Power Ltd, Bhopal vs. The ACIT, Central Circle-1, Bhopal

Appeal is dismissed

ITA 68/IND/2023[2015-16]Status: DisposedITAT Indore24 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151Section 56(2)(viib)Section 69C

73/Ind/2023- A.Y. 2015-16 Commissioner or Commissioner for issuance of notice after expiry of four years, section 151(2) permits issuance of notice within four years after obtaining approval from much lower-level authority, namely Joint Commissioner. When the law provides a clear-cut mechanism, the statutory function ... done at all; there cannot be any other option. Ld. AR submitted that if the AO is allowed to obtain approval within four years from lower-authority in terms of section 151(2), just keep such approval in file and subsequently issue notice after four years, it would

Naz Shazia, Moradabad vs. ITO Ward 1(1), Moradabad

In the result, the appeal of the assessee is allowed

ITA 1831/DEL/2023[2014-15]Status: DisposedITAT Delhi18 Jan 2024AY 2014-15

Bench: Shri M. Balaganeshnaz Shazia, Vs. Ito, Anwar House, Ground Ward-1(1), Floor, Pandit Nagla Mini Moradabad Bye Pass Road, Moradabad Pan: Bbwps217R Assessee By : Shri V. K. Tulsian, Ca Revenue By: Shri Om Parkash, Sr. Dr Date Of Hearing 15/01/2024 Date Of Pronouncement 18/01/2024

For Appellant: Shri V. K. Tulsian, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 234BSection 69A

assessment year under consideration is deemed to be a case where income chargeable to tax has escaped assessment. This case is within four years from the end of the assessment year under consideration. Hence, necessary sanction to issue, the notice u/s 148 has been obtained separately from Joint Commissioner

Bcp V Singapore Fvci Pte Ltd., Singapore vs. ACIT Circle Int Tax 1(1)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 449/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Jan 2024AY 2017-18

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Porus Kaka, Sr. AdvFor Respondent: Sh. Vizay B. Vasanta, Sr. DR
Section 148Section 234ASection 234BSection 270A

escaped assessment." 6 BCP V Singapore FVCI Pte. Ltd. 6.3 The assessment/re-assessment proceedings in this case for A.Y. 2017-18 pertain to period within four years from the end of relevant assessment years at the time of issue of notice, necessary sanction has to be obtained from Addl. Commissioner

Reena Jain, Kolkata vs. ITO, Ward-37(1), Kol, Kolkata

In the result, the appeal of the assessee is hereby allowed

ITA 503/KOL/2023[2015-16]Status: DisposedITAT Kolkata09 Jan 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal]

Section 142(1)Section 147Section 148Section 151Section 68

needed to be a case where income chargeable to tax has escaped assessment. 6 AY: 2015-16 Reena Jain This case is within four years from the end of the assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 is requested before Addl

Assistant Commissioner of Income Tax, Central Circle-5(4), Mumbai vs. Shri Nishant Kanodia, Mumbai

ITA 2155/MUM/2023[2013-2014]Status: DisposedITAT Mumbai08 Jan 2024AY 2013-2014

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Ajay R. Singh a/wFor Respondent: Shri S. Sribivasu
Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 9A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Shrifal Impex Private Limited, Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 250/SRT/2023[2014-15]Status: DisposedITAT Surat29 Dec 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice". Authority prescribed for grant of sanction/approval within four years of relevant assessment year is the 'Joint Commissioner of Income Tax'. Under section 151(2) of the Act of 1961 the Joint Commissioner

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 191/SRT/2023[2012-13]Status: DisposedITAT Surat29 Dec 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice". Authority prescribed for grant of sanction/approval within four years of relevant assessment year is the 'Joint Commissioner of Income Tax'. Under section 151(2) of the Act of 1961 the Joint Commissioner

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 190/SRT/2023[2011-12]Status: DisposedITAT Surat29 Dec 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice". Authority prescribed for grant of sanction/approval within four years of relevant assessment year is the 'Joint Commissioner of Income Tax'. Under section 151(2) of the Act of 1961 the Joint Commissioner

Arun Kumar Mittal, Delhi vs. ACIT, Central Circle-31, Delhi

In the result, appeal is allowed as indicated above

ITA 2970/DEL/2022[2019-20]Status: DisposedITAT Delhi20 Dec 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2019-20

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Sh. Zafarul Haque Tanweer, CIT-DR
Section 127Section 143(2)Section 143(3)Section 153ASection 153DSection 69A

concerned, provision under Section 151 of the Act of 1961 provides for "sanction for issuance of notice". Authority prescribed for grant of sanction/approval within four years of relevant assessment year is the 'Joint Commissioner of Income Tax'. Under Section 151 (2) of the Act of 1961 the Joint Commissioner

Bajaj Auto Ltd., Mumbai vs. DCIT -Ltu -1, Mumbai

In the result we find that in absence of tangible material, the reopening of assessment cannot be made

ITA 3949/MUM/2019[2010-11]Status: DisposedITAT Mumbai29 Nov 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Dy. Commissioner Of Bajaj Auto Limited 2N D Floor, Bajaj Bhawan, Income-Tax, Vs. 226, Nariman Point, Large Taxpayer Unit-1 Mumbai-400 021 Mumbai-400 005 (Appellant) (Respondent) Pan No. Aadcb2923M

For Appellant: Shri Percy Pardiwala, Sr. Adv. &For Respondent: Shri S Srinivasu, CIT DR
Section 143(3)Section 145(2)Section 147

possession of a ‘tangible material’. Such is Bajaj Auto Ltd; A.Y. 2010-11 the requirement for reopening of the assessment whether within four years or within six years from the end of the assessment year. 030. For the first issue of reopening with respect to the not including the valuation

Shri Ravjibhai B Dhameliya, Surat vs. DCIT, Circle-2(1)(2), Surat

In the result, assessee`s appeal for both the assessment years, that is,

ITA 124/SRT/2020[2011-12]Status: DisposedITAT Surat06 Nov 2023AY 2011-12

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri P. M. Jagasheth, CA and Shri Sapnesh Sheth, CAFor Respondent: Shri Airiju Jaikaran, CIT(DR)
Section 143(3)Section 148Section 151(1)

reopening of the assessment was made by the assessing officer for both assessment years, 2010-11 and 2011- 12, on 30.03.2017, which is within four years from the end of the relevant assessment year, hence in assessee`s case there was no requirement to sanction of notice by Principal Commissioner

ACIT, Circle-3(3), Surat vs. Shri Ravjibhai Becharbhai Dhameliya, Surat

In the result, assessee`s appeal for both the assessment years, that is,

ITA 122/SRT/2020[2011-12]Status: DisposedITAT Surat06 Nov 2023AY 2011-12

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri P. M. Jagasheth, CA and Shri Sapnesh Sheth, CAFor Respondent: Shri Airiju Jaikaran, CIT(DR)
Section 143(3)Section 148Section 151(1)

reopening of the assessment was made by the assessing officer for both assessment years, 2010-11 and 2011- 12, on 30.03.2017, which is within four years from the end of the relevant assessment year, hence in assessee`s case there was no requirement to sanction of notice by Principal Commissioner

DCIT, Circle-3(3), Surat vs. Shri Ravjibhai Becharbhai Dhameliya, Surat

In the result, assessee`s appeal for both the assessment years, that is,

ITA 304/SRT/2019[2010-11]Status: DisposedITAT Surat06 Nov 2023AY 2010-11

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri P. M. Jagasheth, CA and Shri Sapnesh Sheth, CAFor Respondent: Shri Airiju Jaikaran, CIT(DR)
Section 143(3)Section 148Section 151(1)

reopening of the assessment was made by the assessing officer for both assessment years, 2010-11 and 2011- 12, on 30.03.2017, which is within four years from the end of the relevant assessment year, hence in assessee`s case there was no requirement to sanction of notice by Principal Commissioner

Shri Ravjibhai Becharbhai Dhameliya, Surat vs. Income Tax Officer Ward-3(1(1), Surat

In the result, assessee`s appeal for both the assessment years, that is,

ITA 239/SRT/2019[2010-11]Status: DisposedITAT Surat06 Nov 2023AY 2010-11

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri P. M. Jagasheth, CA and Shri Sapnesh Sheth, CAFor Respondent: Shri Airiju Jaikaran, CIT(DR)
Section 143(3)Section 148Section 151(1)

reopening of the assessment was made by the assessing officer for both assessment years, 2010-11 and 2011- 12, on 30.03.2017, which is within four years from the end of the relevant assessment year, hence in assessee`s case there was no requirement to sanction of notice by Principal Commissioner

Income Tax Officer-1(1)(1), Mumbai vs. Sohni Depak Tanna, Mumbai

In the result appeal of the learned assessing officer and cross objections of the assessee are dismissed

ITA 2245/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Oct 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm C.O.No. 135/Mum/2022 (Assessment Year 2014-15) Sohni Dipak Tanna Ito 1(1)(1), Mumbai 2Nd Floor, Tanna House, 11A, 534, 5Th Floor, Aaykar Bhavan, Nathlal Parekh Marg, M. K. Road, Vs. Mumbai-400020 Mumbai-400001 (Appellant) (Respondent) Pan No. Acept3611J Sohni Dipak Tanna Ito 1(1)(1), Mumbai 2Nd Floor, Tanna House, 11A, 534, 5Th Floor, Aaykar Bhavan, Nathlal Parekh Marg, M. K. Road, Vs. Mumbai-400020 Mumbai-400001 (Appellant) (Respondent) Pan No. Acept3611J Assessee By : Shri. Madhur Agrawal & Pankaj Jain Revenue By : Shri. Kishor Dhule Date Of Hearing: 03.10.2023 Date Of Pronouncement : 30.10.2023

For Appellant: Shri. Madhur Agrawal & PankajFor Respondent: Shri. Kishor Dhule
Section 10Section 143Section 147Section 148Section 68

assessment year under consideration is deemed to be a case where income chargeable to tax has escaped assessment. This case is within four years from the end of the assessment year under consideration. Hence necessary sanction to issue the notice under section 148 has been obtained separately from the joint ... assessed under section 143 (3) of the act. The notice under section 148 of the act was issued on 5/3/2019 which is within four years of the end of the assessment year in which the income was first assessable. For reopening of the assessment there was a tangible material available

Deputy Commissioner of Income Tax, Circle-1(1), Raipur vs. Shri Rakesh Saraogi, Raipur

In the result, the appeal of the revenue is partly allowed in terms of our aforesaid observations

ITA 98/RPR/2023[2013-14]Status: DisposedITAT Raipur27 Oct 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 98/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Rakesh Saraogi Prop. M/S. Madan Construction, Subhash Road, Gunj Para, Raipur (C.G.) Pan : Ajjps3803P ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(2)Section 143(3)Section 80I

local authority on or after the 1st day of April, 2004 but not later than the 31st day of March, 2005, within four years from the end of the financial year in which the housing project is approved by the local authority; 9 DCIT, Circle-1(1), Raipur Vs. Shri

Haier Appliances India Private Limited, Delhi vs. DCIT, It & Tp Delhi 2(1)(1), New Delhi

In the result the appeal of the assessee in ITA No

ITA 417/DEL/2022[2017-148]Status: DisposedITAT Delhi17 Oct 2023AY 2017-148

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)Section 254Section 92BSection 92F

limit for completion of an assessment under Section 34(2) of the Income Tax Act, 1922, which provided that it shall be made "within four years from the end of the year in which the income, profit and gains were first assessable", it was held that the time limit

D.C.I.T. - 15(3)(2), Mumbai vs. Sadguru Management Consultancy P. Ltd., Mumbai

In the result ground of appeal filed by the assessee under rule 27 of ITAT Rule is allowed and appeal of the revenue is dismissed

ITA 6323/MUM/2017[2009-10]Status: DisposedITAT Mumbai27 Sept 2023AY 2009-10

Bench: Aby T Vakery & Shri Amarjit Singhdy. Commissioner Of Vs. Sadguru Management Income Tax- 15(3)(2) Consultancy Pvt. Ltd Room No. 451, 4 Th Floor, 7, Gagangiri, Plot No. 47, Aayakar Bhavan, Sector 17, Vashi, Navi Maharshi Karve Road, Mumbai- 400703 Mumbai- 400020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aamcs1626F Appellant .. Respondent

For Appellant: Shri Dharan Gandhi, ARFor Respondent: Shri Suresh D. Gaikwad, DR
Section 132Section 143(1)Section 148Section 250Section 68

ITAT rule, 1963, we have perused the copy of 148 notice placed in the paper book. Since the impugned notice is issued within four years from the end of relevant assessment year on 10 Sadguru Management Consultancy P. Ltd 30.03.2015, therefore it is required to issued after obtaining the approval

M/S. Larsen & Tourbro Ltd., Mumbai vs. Dy Commissioner of Income Tax, Central Circle-2(2) & 5(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 1009/MUM/2022[2003-04]Status: DisposedITAT Mumbai26 Sept 2023AY 2003-04

Bench: Aby T Vakery & Shri Amarjit Singhlarsen & Toubro Ltd Vs. Deputy Commissioner Of L&T House, N M Marg Income Tax, Circle- (5)(4), Ballard Estate, Fort Mumbai (Erstwhile Mumbai- 400001 Income Tax Officer- 2(2) Room No. 1927, 19Th Floor, Air India Building, Nariman Point, Mumbai- 400021

For Appellant: Shri J.D. Mistri & MadhurFor Respondent: Shri Sushil K. Poddar, CIT-DR
Section 143(3)Section 147Section 148Section 234BSection 250Section 35Section 80Section 801ASection 80I

Larsent Toubro Ltd accepted the contention of the assessee stating that notice u/s 148 of the Act was issued within four years as per the provisions of section 147 of the Act. The re-assessment u/s 147 r.w.s. 143(3) of the Act was finalized on 30.12.2008 and total income ... other hand the Ld. Department representative has referred the observation of the assessing officer that AO can issue notice within four years from the end of the relevant assessment year even if there 8 M/s. Larsent Toubro Ltd is no failure on the part of the assessee to disclose fully