2023 (11) TMI 1255

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..... e looked into - Reopening after a period of 7 years i.e. on the last date of 7th year has reopened the case u/s. 147 by issuing notice u/s 148 - appellant argued that an issue of limitation was specifically raised as a ground before the Income Tax Appellate Tribunal but the Tribunal did not examine this issue and decided the case on its merits HELD THAT:- From the record pleadings made by the appe .....

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..... which is not there. Income tax appeal stands dismissed. - HON'BLE THE ACTING CHIEF JUSTICE MR. MANINDRA MOHAN SHRIVASTAVA And HON'BLE MRS. JUSTICE SHUBHA MEHTA For the Appellant : Mr. Sanjeev Singhal For the Respondent : Mr. Shantanu Sharma with Ms. Bhavna Laddha and Mr. Anurag Mathur ORDER Learned counsel for the appellant presses this appeal on the proposed substantial questions of law .....

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..... support of the contentions, he relies upon the judgment of the High Court of Gujarat at Ahmedabad in the case of Kanubhai M Patel HUF Vs. Hiren Bhatt or His Successors to Office 4 respondent(s) reported in SCA/5295/2010 decided on 13.07.2010. From the record pleadings made by the appellant, it does not appear that the issue of limitation has been raised on a factual foundation that though notice .....

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