Held that notice had been issued beyond the statutory period of four years as notice under section 143(2) of the Act was issued beyond the prescribed time limit in the Act. Quashing of reassessment is held to be valid. Tribunal also held that the Department’s appeals fell under clause 10(e) of the CBDT Circular No. 3 of 2018, dated July 11, 2018 (2008) 405 ITR 29 (St) as amended by Circular No. 17 of 2019, dated August 8, 2019(2019) 416 ITR 106 (St) and should not be dismissed on account of low tax effect. (AY.2010-11, 2011-12)
ITO v. Manjil Dineshkumar Shah (2022) 94 ITR 68 (SN) (Ahd.) (Trib.)
S. 143(2) : Assessment-Notice-Failure to issue notice-Reassessment is bad in law-Monetary limit-Information from Sales tax department falls with in the exception-Appeal is maintainable. [S. 147, 148, 268A]