2009 (7) TMI 147

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.... JUDGMENT The judgment of the court was delivered by ADARSH KUMAR GOEL J—The Income-tax Appellate Tribunal, Amritsar Bench, Amritsar, has referred the following question of law for opinion of this court, arising out of its common order dated March 9, 1994, in I. T. A. Nos. 221 and 381 (ASR)/1985 in respect of the assessment year 1981-82: "Whether, on the facts and in the circumstance....

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.... Explanation 1, clause (iv) below section 153, it was held that the period up to 180 days from the date on which the draft assessment order is forwarded by the Income-tax Officer to the assessee up to the date on which directions are received is to be excluded. In the present case, the draft assessment order was prepared on March 10, 1984, and permission was received from the Inspecting Assistant ....