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TMI Blog2009 (9) TMI 139X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome on September 28, 2001, in respect of the assessment year 2001-02. The last date for issuing of notice under section 143(2) was September 30, 2002, i.e., within 12 months from the month in which the return had been filed. 2. Admittedly, no steps were initiated by the Assessing Officer before September 30, 2002. The first ever notice under section 143(2) was prepared on the last date, i.e., S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hours. The Inspector affixed the notice on the front gate of the premises of the assessee-company. It is rightly held by the Income-tax Appellate Tribunal that it was not a proper service of the notice upon the assessee. Since September 30, 2002, was the last date by which such a notice under section 143(2) of the Act had to be served, the proceedings which were taken thereafter were clearly time ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5, 2009, in a batch of appeals, viz., in I. T. A. No. 200/2008 CIT v. Pawan Gupta [2009] 318 ITR 322. 5. Finally, she submitted that in all the appeals, the assessee had participated in the block assessment proceedings. It is not the case that no opportunity of being heard had been given to the assessee. Virtually in all the cases the Assessing Officer had issued notices to the assessees requisit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Chapter XIV-B. if the Assessing Officer, on receipt of the return of undisclosed income in Form 2B from the assessee, is satisfied with the same as reflecting the true state of affairs then it is not necessary for him to embark upon any further enquiry or investigation. No further information or explanation is called for from the assessee. In such an eventuality he can straightaway pass the ord ..... X X X X Extracts X X X X X X X X Extracts X X X X
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