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The High Court of Rajasthan dismissed the Revenue's application under section 256(2) of the Income-tax Act, 1961. The Tribunal's decision to reject the Revenue's appeal and application for reference under section 256(1) was upheld. The court found that the question of law based on section 147(b) did not arise for decision as it was raised belatedly and not communicated to the assessee during the assessment reopening. The application was rejected with no costs.
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