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    <title>1984 (3) TMI 107 - ITAT BOMBAY-A</title>
    <link>https://www.taxtmi.com/caselaws?id=57952</link>
    <description>Even where the statute prescribes no express limitation period, tax reassessment must be initiated within a reasonable time, and inordinate delay must be satisfactorily explained. Here, excess profits tax reassessment was commenced only after about 22 years and completed after about 24 years, long after the related income-tax reassessment had become final. The explanation that the department awaited finality of the income-tax proceedings was held inadequate because the delay had to be justified component-wise and the Excess Profits Tax Act involved distinct issues and evidence. The unexplained delay also caused prejudice as relevant material was no longer available. The reassessment was therefore unsustainable and the assessee succeeded.</description>
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    <pubDate>Mon, 19 Mar 1984 00:00:00 +0530</pubDate>
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      <title>1984 (3) TMI 107 - ITAT BOMBAY-A</title>
      <link>https://www.taxtmi.com/caselaws?id=57952</link>
      <description>Even where the statute prescribes no express limitation period, tax reassessment must be initiated within a reasonable time, and inordinate delay must be satisfactorily explained. Here, excess profits tax reassessment was commenced only after about 22 years and completed after about 24 years, long after the related income-tax reassessment had become final. The explanation that the department awaited finality of the income-tax proceedings was held inadequate because the delay had to be justified component-wise and the Excess Profits Tax Act involved distinct issues and evidence. The unexplained delay also caused prejudice as relevant material was no longer available. The reassessment was therefore unsustainable and the assessee succeeded.</description>
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      <pubDate>Mon, 19 Mar 1984 00:00:00 +0530</pubDate>
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