1994 (3) TMI 50

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....(1)(c) of the Income-tax Act and, consequently, the assessment order passed by the Income-tax Officer was within time ?" The brief facts of the case are that the assessee has not filed any return in respect of its income under section 139(1) or section 139(4) of the Income-tax Act 1961 (hereinafter called as "the Act"), and no notice was issued under section 139(2) to the assessee. Subsequently, the Income-tax Officer issued a notice under section 148 of the Act which was served on the assessee on January 5,1977. In pursuance of the said notice, the return was required to be filed on or before February 7, 1977, but no return was filed till the last date. However, it was filed an February 14, 1977. The contention of the assessee was that ....

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....47 after the expiry of two. years from the end of the financial year in which the notice under section 148 was served : Provided that where the notice under section 148 was served on or before the 31st day of March, 1987, such assessment, reassessment or recomputation may be made at any time up to the 31st day of March, 1990." Sub-section (2) of section 153 has provided that no order of assessment, reassessment or recomputation shall be made under section 147 after the expiry of two years from the end of the financial year in which the notice under section 148 was served. This section refers to assessment, reassessment or recomputation. The provisions of section 153(1) provide that no order of assessment shall be made under section 14....