Dismissing the writ petition against the reassessment notice the Court held that the disputed facts cannot be adjudicated in writ proceedings. As regards the limitation the Court held that in the absence of any order communicated the Assessing Officer, it was not possible for the department to act in a particular manner. Order passed based on the final assessment order was within limitation period and not barred by limitation. (AY. 2007-08)
Madras Race Club v. Dy.CIT (2021) 203 DTR 338 / 322 CTR 392 (Mad.)(HC) Editorial : Affirmed by division Bench Madras Race Club v. Dy. CIT (2021) 206 DTR 297 / 323 CTR 180 (Mad.)(HC)
S. 147 : Reassessment-With in four years-Disputed facts-Alternative remedy-Order is not barred by limitation-Writ is not maintainable. [S. 148, 153(2), Art. 226]