9911796707
TMI Blog2007 (9) TMI 618X X X X Extracts X X X X X X X X Extracts X X X X ..... ), the revenue is aggrieved by an order dated 5-1-2007 passed by the Income-tax Appellate Tribunal, Delhi Bench 'B' in ITA No. 901/Delhi/2004 relevant for the assessment year 1992-93. 2. The only question that arises in this case is whether the notice to the assessee under section 147/148 of the Act within the time as prescribed by law. 3. The proviso to section 147 of the Act is that no action ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... necessary for the assessment for the relevant assessment year. The Tribunal accordingly came to the conclusion that the action initiated by the revenue under section 147/148 was barred by limitation. It may be noted that relevant to the assessment year 1994-95, the Tribunal had, under the circumstances, passed a similar order. 6. We find that this is a pure question of fact. In our opinion, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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