COMMISSIONER OF INCOME TAX-III vs. M/S. CALCUTTA KNITWEARS, LUDHIANA

unexplained investment) and Rs.5,71,172/- (profit element)) by order dated 08.02.2008. The assessing officer is of the view that Section 158BE of the Act does not provide for any limitation for issuance of notice and completion of the assessment proceedings under Section 158BD of the Act and therefore a notice could be issued even after completion of the proceedings

THE COMMISSIONER OF INCOME TAX JAIPUR vs. PRAKASH CHAND LUNIA (D) THR LRS

Bench: HON'BLE MR. JUSTICE M.R. SHAH

unexplained income, expenditure etc., it can never be said that the same would be brought under Section 37(1) of the Act, despite the fact that the objective behind both the provisions are overlapping with some connection. CIVIL APPEAL NO. 7689-7690 OF 2022 8 Section 115BBE being a subsequent legislation, the true meaning of Section