1984 (9) TMI 27

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.... of the notices issued under section 281 B of the Income-tax Act (hereinafter referred to as " the Act by the Income-tax Officer, respondent No. 2, on March 14, 1984, vide which various bank deposits (F.D.Rs.) of the assessee lying in six different banks at Patiala and Chandigarh have been attached. Section 281B of the Act reads as under: "281B. (1) Where, during the pendency of any proceeding ....

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....shall not in any case exceed two years." It is contended by Mr., Mahajan, learned counsel for the petitioner, that the impugned notices have been issued without applicability of mind by the Income-tax Officer, respondent No. 2. It is also submitted by the learned counsel that after the issuance of notices, six months' period has expired and that no extension has been granted by the Commissioner....

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....eriod could be extended by the Commissioner in exercise of his powers under sub-section (2) of section 281B of the Act, after recording reasons for the extension of such period. In the instant case, the period of six months has since expired. Mr. Ashok Bhan, Senior Advocate, learned counsel for the Department has not been able to produce today before us any order of the Commissioner by which the e....