2005 (7) TMI 58

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..... on March 26, 1999, had expired on the date the second notice, dated March 29, 2001, was issued to it. - The fact of the matter, however, appears to be that the period prescribed for completion of the assessment proceedings was two years and would have expired on March 31, 2001. It would, therefore, be more appropriate to let the Tribunal to examine that issue afresh and to pass a fresh order. We, .....

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..... as contended by learned counsel for the appellant that the Tribunal proceeded on the assumption that the period for completion of the assessment proceedings was one year from the end of the financial year in which the notice was issued. He urged that the period for completing the assessment proceedings was two years, which would have in the instant case expired on March 31, 2001, and not on March .....

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..... e Tribunal does appear to have proceeded on the assumption that the period for completion of the assessment proceedings was one year from the end of the financial year in which the notice was issued. The fact of the matter, however, appears to be that the period prescribed for completion of the assessment proceedings was two years and would have expired on March 31, 2001. It would, therefore, be m .....

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