BIMAL KUMAR DROLIA,HOWRAH vs. ITO, WARD-43(2), KOLKATA
In the result, the appeal filed by the assessee is dismissed
ITA 347/KOL/2024[2009-10]Status: DisposedITAT Kolkata18 Jul 2025AY 2009-10
Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra
Section 143(2)Section 147Section 147(6)Section 148Section 250Section 34
going to end on 31-3-1970. On that day, i.e., 31-3-1970, the ITO issued a notice to the assessee under section 147(6) by registered post which was received by the assessee on 4-3-1970. On writ, the High Court relied upon the decision ... period. Therefore, service of notice within limitation was the foundations of jurisdiction. The High Court, accordingly, quashed the notice for reassessment issued under section 147(6). On appeal to the Hon'ble Supreme Court, it is held as under:
“The scheme of the 1961 Act so far as notice