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2019 (8) TMI 358

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....ld liable for concealment of income of Rs. 33,20,000/-. (2) Ram Singh was the original assessee. (3) For the Assessment Year 2010-11, notice was issued on 30.03.2017 under Section 148 of 1961 Act. (4) Though a cavil is raised by the petitioner that no notice was issued on 30.03.2017. And that the only notice which was issued was on 09.12.2017 with the publication of it in the newspaper. (5) To resolve this controversy, we summoned the original record; wherein, we find that the notice under Section 148 of 1961 Act was issued to Ram Singh vide speed post No.E1936505274IN on 30.03.2017 which returned unserved on 03.04.2017. It is, however, borne out from the record that the proceedings were initiated on 30.03.2017 which are reproduced as u....

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....rusal of bank statement Rs. 74,00,000/- was found to be deposited on 13.07.2009 in the account. And as no document was furnished in respect of Rs. 33,20,000/-, the assessee was held to be liable for concealment of the said income. Revision thereagainst was dismissed vide impugned order. (10) Section 148 of the 1961 Act envisages issuance of notice where income has escaped assessment. (11) Section 149 of the 1961 Act stipulates the time limit within which the notice under Section 148 can be issued. (12) Clause (b) of sub-section (1) of Section 149 of the 1961 Act stipulates: "(1) No notice under section 148 shall be issued for the relevant assessment year- (a) xx xx xx (b) if four years, but not more than six years, have elapsed fro....

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....sentatives.- (1) Where a person dies, his legal representatives shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner and to the same extent as the deceased. (2) For the purpose of making an assessment (including an assessment, reassessment or recomputation under section 147) of the income of the deceased and for the purpose of levying any sum in the hands of the legal representative in accordance with the provisions of subsection (1),- (a) any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of the d....