2008 (9) TMI 151

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....peal under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), against the order dated February 28, 2007, passed by the Income-tax Appellate Tribunal, Delhi Bench, New Delhi (hereinafter referred to as "the Tribunal"), in I. T. A. No. 3874/Delhi/2006 for the assessment year 1993-94 proposing the following substantial questions of law: "1. Whether, on the facts and cir....

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....ated read with the provisions of section 150(1)? 4. Whether the initiation of proceedings under section 148 read with section 150(1) can be declared barred by limitation in view of the protection available to the Revenue under section 150(1) of the Income-tax Act, 1961?" 2. The matter emanates from notices dated March 31, 2005, issued to the assessee under section 148 of the Act for the assessme....

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....on 148 are to be regulated by section 149 of the Income-tax Act as in the order passed by the hon'ble judge there is no finding or direction to be basis for a notice within the extended period under section 150(1)." 4. Learned counsel for the appellant has relied on the case of K. M. Sharma v. ITO reported in [2002] 254 ITR 772. We find that the said judgment is not applicable since it laid down ....