H.S. BAWA Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) This petition seeks quashing of notice dated March 29, 1989, annexure P-6, under Section 148 of the Income-tax Act, 1961 (for short, "the Act") for reopening the assessment for the assessment year 1980-81.

(2.) The main contention raised in the petition is that reassessment proceedings could be initiated only within four years from the end of the relevant assessment year as laid down under Section 149(1)(b) of the Act while in the present case the impugned notice is far beyond the said period.

(3.) Learned Counsel for the Revenue is unable to dispute the factual and legal submission put forward on behalf of the petitioner.