AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
2020 (2) TMI 1100
X X X X Extracts X X X X
X X X X Extracts X X X X
....nbsp; Respondents Through Mr. Raghvendra Singh, Sr. Standing counsel with Mr. Shalinder Singh and Mr.Ajinkya Tiwari, Advs. for R-1. O R D E R CM APPL. 6086/2020 (exemption) 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. W.P.(C) 1744/2020, CM APPL. 6085/2020 (Stay) 3. Mr. Vohra, learned senior counsel points out that the Reve....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d notice, since it is the responsibility of the Respondents to ensure that they are not met with a fait accompli, in the eventuality of the aforesaid pending appeal being rejected by this Court. If we were not to admit the appeal and reject the same at the threshold, the Respondents would have been entitled to issue the notice in question within the period of limitation, since the earlier assessme....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ereafter, a fresh notice was issued under Section 148 of the Act for reopening of assessment. It was in this background that the Punjab & Haryana High Court held that the proceedings could not be reopened since the original assessment had not been completed within the period of limitation and was time barred. In the present case, the notice under Section 148 had been issued to make assessment a....
X X X X Extracts X X X X
X X X X Extracts X X X X
....nsideration before this Court against the order of the ITAT whereby the assessment order has been quashed on a technical ground. Revenue is expected to ensure that they initiate a proceeding, so that, in the eventuality of the aforesaid appeal of the Revenue being dismissed by this Court, they are not faced with a situation that initiation of fresh action under Section 148 is barred by limitation.....