9911796707
TMI Blog2014 (12) TMI 1335X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessing authority, that too, after taking note of the assessment orders passed subsequent to the said order for the subsequent years, the assessment is sought to be reopened after a period of years. Four years is the period of limitation prescribed for the re-opening of the assessment in the sense, an assessment cannot be reopened unless the case falls within one of the exceptions mentioned in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that case would not fall under Section 147 - Decided in favour of the assessee. - ITA No. 220/2009 - - - Dated:- 15-12-2014 - Mr N. Kumar And Mr B. Manohar, JJ. Sri K V Aravind, Adv. For The Appellant. Sri T Suryanarayana, Adv. For M/s King And Partridge For The Respondent. JUDGMENT The revenue has preferred this appeal against the concurrent findings recorded by the appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny invention by the assessee or by BOSCH. The development agreement entered in to between the assessee company with BOSCH does not indicate any invention involved. Such technical services fee received is removed from the ambit of Section 80(O) of the Act with effect from 01.04.1998. The assessee is not holding any patent, design or registration. Therefore, the assessing authority was of the view t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s passed subsequent to the said order for the subsequent years, the assessment is sought to be reopened after a period of years. Four years is the period of limitation prescribed for the re-opening of the assessment in the sense, an assessment cannot be reopened unless the case falls within one of the exceptions mentioned in the first proviso. 4. If an assessment is to be reopened, the assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
