TaxTMI 
TaxTMI 
1993 (1) TMI 48
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....ncome-tax Appellate Tribunal has referred the following question at the instance of the Revenue : "Whether the Tribunal was justified in law in holding that the extended time-limit for completing the assessment under section 153(1)(b) was not available to the Income-tax Officer as he had not come to grips with the alleged items of concealment before the normal period of limitation ran out ? " Th....
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....n November 19, 1976, when the Income-tax Officer again fixed the cases for the said two years, he discussed the cases with the assessee. The Income-tax Officer completed the assessments for both the assessment years on March 7, 1977, determining the income at Rs. 62,450, for the assessment year 1972-73 and Rs. 56,580 for the assessment year 1973-74. It may be noted here that proceedings under sect....
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....271(1)(c) was attracted in both the years. He held that the Income-tax Officer did not record any findings or bring any material on record within the normal period of time (of one year reckoned from the date of filing of the returns of income) to show that the assessment involved were cases of concealment. In both the years, the limitation under section 153(1)(c) of one year expired on January 5, ....
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....er and dismissed the Departmental appeals. The Tribunal upheld the Appellate Assistant Commissioner's finding that, as the Income-tax Officer had not brought any material on record within the normal period of limitation for completing assessments for coming to a prima facie conclusion that there was any concealment, therefore, the extended time-limit under section 153(1)(b) was not available to th....