Dismissing the appeal of the assessee the Court held that the record did not show that the issue of limitation had been raised before the Tribunal on a factual foundation that though notice under section 148 of the Income-tax Act, 1961 bore the date March 31, 2017, it was not issued on that date but it was put in the course of dispatch after that date. Question of fact. No substantial question of law.
Kamaruddin Mansori v. ITO (2024) 470 ITR 570 (Raj) (HC) Editorial : SLP dismissed, Kamaruddin Mansori v. ITO (2024)470 ITR 572 (SC)
S. 148 : Reassessment-Notice-Limitation-Factual finding-Dispatch date-No substantial question of law.[S. 147, 260A]
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