COMMISSIONER OF INCOME TAX Vs. ARIHANT BUILDERS

JUDGEMENT

(1.) SUBSTANTIAL question of law :

(2.) IT is only after the expiry of the time permissible for that date, though after the expiry of the time permissible for issuance of notice under ss. 143(2) and 143(3), the AO had shown in the return was not correct, and treated it to be escapement of income.

(3.) JAMES Joseph O' Gorman (1993) 204 ITR 454 (Cal), so also the judgments of this Court in CIT vs. Pratap Singh, Amroo Singh, Rajendra Singh & Deepak Kumar (1993) 200 ITR 788 (Raj), CIT vs. Smt. Prem Kumari Surana (1994) 206 ITR 715 (Raj), Sardar Kehar Singh vs. CIT (1992) 92 CTR (Raj) 88 and the judgment of Gujarat High Court in Dinkarrai Anantrai Mankad vs. ITO (1985) 155 ITR 406 (Guj). In appeal, the learned Tribunal upheld the same.