2013 (12) TMI 1260

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....unath, J. Heard Sri. A. Shankar, learned Counsel for appellant and Sri. Y.V. Raviraj, learned Standing Counsel for respondents. 2. Challenging the findings of the order passed by the Commissioner of Income Tax (Appeals) Belgaum, in ITA Nos.42 & 43/BGM/2005-06 dated 18.1.2006, for the assessment year 2000-2001, the appellant, had filed appeal before the Income Tax Appellate Tribunal, Panaji B....

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....n 6.2.2004 notice u/s 148 of the Income Tax Act was issued for reassessment when the original return of income was filed on 28.3.2002 remained undisputed. Notice was served upon the appellant u/s 148 of the Income Tax Act on 17.2.2004. A notice u/s 143(2) and 142 came to be issued on 6.12.04. The order of assessment was passed on 24.3.2005. 5. Aggrieved by the order of assessment dated 24.3 200....

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.... law and barred by time and it is also his further contention that no proper reasons recorded by the Assessing Officer for reopening the case. 9. Mr Raviraj, the learned Counsel appearing for the department contents that, both grounds are not tenable because notice has been issued within the stipulated time and cannot be treated as barred by time. He has also furnished reasons recorded by the a....