2010 (4) TMI 45

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....at Kapoor, Mr. Ankit Gupta, Mr. Achin Geol and Ms. Swati Gupta. JUDGEMENT BADAR DURREZ AHMED -  These appeals filed by the revenue arise out of a common order dated 05.03.2009 passed by the Income Tax Appellate Tribunal in the appeal filed by the revenue and the cross objections preferred by the Respondent/Assessee. 2. In the said cross objections, the Respondent/Assessee raised t....

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....dicated that although no specific period of limitation has been prescribed or indicated under Section 201 and 201(A), a reasonable time limit has to be adopted. In that context, it examined the provisions of Section 153(1)(a) and came to the conclusion:- "18. In so far as the Income-tax Act is concerned, our attention has been drawn to section 153(1)(a) thereof which prescribes the time limit f....

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....bunal has, in a series of decisions, some of which have been mentioned in the order which is under challenge before us, taken the view that four years would be a reasonable period of time for initiating action, in a case where no limitation is prescribed. 20. The rationale for this seems to be quite clear-if there is a time limit for completing the assessment, then the time limit for initiating....