2010 (9) TMI 97

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....ection 143 (1)(a) of the Income Tax Act (the Act) on 1.11.1993. 2. Subsequently, a search was made at the premises of the respondent on 17.10.1994 and a notice for reassessment under Section 148 of the Act was issued. In the reassessment proceedings, the assessee was assessed on 27.12.1996 on an income of Rs.2,28,18,870/-. The assessee filed an appeal. His appeal was dismissed. He subsequently ....

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.... the penalty was imposed on 27.11.2005. The penalty order was set aside by the Tribunal vide order dated 4.8.2006 on the ground that it was barred by time under Section 275 (1) (a) of the Act. Hence the present appeal by the Department. 6. According to the appellant; The limitation ought to have been taken from the order dated 28.2.2005; The penalty was not barred by time. 7. We have heard S....