TIMES INTERNET LIMITED (REPRESENTATIVE ASSESSEE OF WILLOW TV INTERNATIONAL LTD),NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI
Appeal is allowed
ITA 2239/DEL/2024[2016-17]Status: DisposedITAT Delhi21 Mar 2025AY 2016-17
Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2016-17 M/S. Times Internet Ltd. Vs. Dcit, (Representative Assessee Of New Delhi Willow Tv International Ltd.), Express Building, 9-10 Bahadurshah Zafar Marg, New Delhi Pan: Aabct1559M (Appellant) (Respondent) Assessee By Sh. Ajay Vohra, Sr. Adv. Sh. Shaurya, Ca Sh. Deepesh Jain, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr)
Section 147Section 148Section 148ASection 149Section 163Section 246
interpretations, one favourable to the asses-see has to be preferred to the one favouring the revenue. The change of language made in sections 149(3) and 163 of the 1961 Act as compared to the corresponding provisions in the 1922 Act is not without meaning and purpose ... provisions of sub-section (2) of section 163
of the 1961 Act. Without deciding this matter, no notice under section 148 read with section 149(3) of the 1961 Act can be issued."
This decision of the Punjab and Haryana High Court came to be considered by the Madras High