2016 (7) TMI 1234

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...., Advocate. For the Respondents: Mr. Somyajit Dasgupta, Advocate, Mrs. Anupa Banerjee, Advocate and Mr. P. Ksarawagi, Advocate. ORDER The Court : The subject matter of challenge is a judgement and order dated 24th August, 2007 passed by the learned Income Tax Appellate Tribunal "D" Bench, Kolkata in I.T.A.No.977/Kol/2007 pertaining to the assessment year 1997-98, by which the learned Trib....

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.... after four years, after 31st March, 1998, the time to pass an order under section 147 had expired on 31st March, 2002. The revenue could have obtained extension provided there was any failure on the part of the assessee to make a return or to disclose fully and truly all material facts necessary for the assessment. It is nobody's case that the assessee had failed to file return or had failed to m....