PRECOT MILLS LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE petitioner challenges the notice issued under s. 148 of the IT Act, 1961.

(2.) THE petitioner had filed the return of income for the asst. yr. 1993-94 on 31st March, 1993. An assessment order under s. 143(3) of the IT Act, 1961, was issued. THE claim towards expenses incurred on repairs/replacement was admitted in the said order. By the impugned notice, the petitioner was informed by the Jt. CIT that he has reason to believe that the income chargeable to tax for the asst. yr. 1993-94 has escaped assessment within the meaning of s. 147 and that he proposed to reassess the income and re compute the loss. THE main submission of learned counsel for the petitioner is that the notice is barred by limitation and is one issued without jurisdiction.