2015 (11) TMI 408

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....n Singh and Chanakya Sharma, Advocates, for the petitioner. N. P. Sahi, Advocate, for the respondent. JUDGMENT 1. This writ petition is directed against the notice dated January 20, 2015, issued under section 201(1)/201(1A) of the Income-tax Act, 1961, pertaining to the financial year 2007-08 relating to the assessment year 2008-09. Earlier, for the same very financial year, a notice had ....

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....ch has been introduced in the said Act with effect from April 1, 2010. The proviso to sub-section (3) stipulates that an order can be passed at any time on or before March 31, 2011. This makes it clear that in so far as the financial year 2007-08 is concerned, in the cir cumstances of this case, no order can be made under sub-section (1) of section 201 after March 31, 2011. Since the notice itself....

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....rom October 1, 2014. Here, the period of limitation has been extended to seven years by the Finance (No. 2) Act, 2014. 4. Mr. Syali, the learned senior counsel appearing on behalf of the petitioner, relied upon the Supreme Court's decision in the case of S. S. Gadgil v. Lal and Co. [1964] 53 ITR 231 (SC) which has been subsequently followed in several other decisions of the Supreme Court in....

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.... that if new information came to the knowledge of the Assessing Officer after the amendment of 2014 then the period of limitation would be seven years for completion of the assessment. However, we need not go into that aspect of the matter inasmuch as, in the present case, no new information has come and the impugned notice that was issued on January 20, 2015, was on the basis of the same informat....