2018 (9) TMI 476

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..... h as reasons for issue of notice under Section 148 of the Income Tax Act for reopening the assessment are dated 21.03.2014, therefore, it could not have been forwarded to the Additional Commissioner or received in the Office of the Additional Commissioner on 20.03.2014. Held that:- Issue notice, returnable in four weeks. There shall be stay of further proceedings, in the meantime. - Petition(s .....

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..... ubmits that this is clearly wrong and it appears that the aforesaid letter dated 21.03.2014 approving the proposal is ante dated. In order to support this submission, he points out that in this letter dated 21.03.2014 it was not possible at all inasmuch as reasons for issue of notice under Section 148 of the Income Tax Act for reopening the assessment are dated 21.03.2014, therefore, it could not .....

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