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TMI Blog2004 (11) TMI 17X X X X Extracts X X X X X X X X Extracts X X X X ..... t the assessees claimed excessive deductions under section 24(1)(vi) of the Act while computing the income from property. The Assessing Officer disallowed the excess claim made by the assessees. In the instant case, admittedly, no notices under section 143(2) of the Act were served on the assessees within the stipulated period of twelve months and, therefore, the proceedings under section 143 of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as under: The assessees filed returns of income and the same were processed under section 143(1)(a) of the Income-tax Act (for brevity "the Act"). The assessees derived income from property and share income from firms. Subsequently, the Assessing Officer issued notices under section 148 of the Act finding that the assessees claimed excessive deductions under section 24(1)(vi) of the Act while co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the following substantial question of law: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in holding that the reopening of the assessment under section 147 of the Act and completion of assessment without issue of notice under section 143(2) of the Act within 12 months is not valid?" The Punjab and Haryana High Court in Vipan Khanna v. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e to an end and the matter becomes final. Hence, applying the ratio laid down by the Punjab and Haryana High Court in Vipan Khanna v. CIT [2002] 255 ITR 220, we are of the view that no substantial question of law arises for our consideration in these appeals. Accordingly, these appeals are dismissed. No costs. Consequently, connected T.C.M.P. Nos. 445 to 447 of 2004 are also dismissed. - - TaxT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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