2023 (5) TMI 881

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....ruchi Aggarwal, Mr. Vineet Garg & Mr. Abhishek Garg, Advs. For the Respondent : Mr. Shailendera Singh, Sr. SC with Ms. Dacchita Shahi, Mr. Viplav Acharya & Mr. Akash Saxena, Advs. JUDGMENT VIBHU BAKHRU, J 1. The petitioner has filed the present petition impugning an order dated 19.12.2017 passed by the Income Tax Settlement Commission (hereafter 'the Commission') under Section 245D(1) ....

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....of the Assessment Years 2012-13, 2013-14 and 2014-15. Admittedly, the time for the Assessing Officer to make an assessment pursuant to the returns filed by the petitioner under Section 139 of the Act in respect of the Assessment Years 2012-13, 2013-14 & 2014-15 had expired and no notice was issued under Section 148 of the Act for assessment, reassessment or re-computation of the petitioner's incom....

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....ssment or reassessment or recomputation under section 147 shall be deemed to have commenced- (a) from the date on which a notice under section 148 is issued for any assessment year; (b) from the date of issuance of the notice referred to in subclause (a), for any other assessment year or assessment years for which a notice under section 148 has not been issued, but such notice co....

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....such proceeding and concluded on the date on which the assessment is made; (iv) a proceeding for assessment for any assessment year, other than the proceedings of assessment or reassessment referred to in clause (i) or clause (iii) or clause (iiia)", shall be deemed to have commenced from the date on which the return of income for that assessment year is furnished under section 139 or in ....