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Issues Involved: Determination of whether the reassessments made under section 147(a) of the Income-tax Act, 1961 for the assessment years 1956-57 to 1958-59 were barred by limitation.
Summary: The assessee, a resident company, challenged the assessments completed by the Income-tax Officer under section 147(a) for the years 1956-57 to 1958-59, claiming they were time-barred under section 153(2). The Commissioner of Income-tax (Appeals) and the Tribunal held that the assessments were completed within the time limit. The assessee contended that the assessments were barred by limitation due to various periods of stay and proceedings. The High Court analyzed the timeline of events, including court stays and directions from the Inspecting Assistant Commissioner, to determine the exclusion periods under Explanation 1 of section 153. The High Court concluded that the assessments were completed well within time, considering the exclusion periods due to court stays and proceedings. The total excluded period was calculated to be 15 years and 139 days, allowing the assessments to be completed by August 17, 1984, which was well within the actual completion date of October 15, 1980. The Court ruled in favor of the Revenue, affirming that the assessments were not barred by limitation. The judgment was unanimous, with both Judges concurring on the decision. In conclusion, the High Court dismissed the assessee's claim, stating that the reassessments for the years in question were completed within the statutory time limit, and no costs were awarded in the matter.
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