complete the assessment or must pass the final orders of assessment within a period of four years from the end of that assessment year ... assessment cannot be said to be a different kind of assessment in the sense that it is neither an assessment under section 23 nor reassessment
four years for assessment and re-assessment. Every action
of audit, enforcement and investigation must culminate in assessment or
re-assessment. He, therefore, submits that ... assessment, and if required, into re-assessment and
confirmation of assessment already done. Therefore, sections 32 and 33
which deal with assessment and re-assessment
assessment or re-assessment under Sections 23 and 34 and is a different kind of assessment altogether, then the question of limitation does ... they authorised the assessment or re-assessment of any person other than the assessee beyond the period of limitation specified in Section 34 in consequence
main ground apart from the merits was that the assessment was barred by limitation, the last date of completion being October ... take up this ground about the impugned assessment being barred by limitation first inasmuch as it felt that if the assessee succeeded on this vital
assessment order being passed. Ordinarily, the assessment is required to be completed within the assessment year compromising of 12 months. In some cases, assessment order ... arise only on passing the assessment order in the assessment year, it is reasonable to hold that the limitation prescribed under Section
total income of the assessee for an assessment year, then, an assessment of such income for another assessment year shall, for the purposes of section ... total income of the assessee for an assessment year, then, an assessment of such income for another assessment year shall, for the purposes of section
assessment dated 27 December
2006. The submission is that in respect of the original order of
assessment dated 27 December 2006, the period of limitation ... under a bar of limitation since
limitation would begin to run from the date on which the original
order of assessment was passed. We must
proceedings for the assessment year 1975-76 and that the assessment order dated September 26, 1978, was not barred by limitation ?"
Common question ... section, i.e., January 1, 1976. If the assessment for any assessment year was barred by limitation under section 153 of the Act, it cannot
person who is intimately connected with the assessment of Sodradevi becouse his assessment depended upon the assessment of Sodradevi and, therefore, with respect to such ... limitation. Admittedly, the initiation of proceedings against the present assessee is beyond the period of limitation for all these years and the assessment proceedings against
April, 1952. The assessment being in respect of the assessment year 1944-45, 8 years from the last day of the assessment year would expire ... relating to the assessment for the assessment year 1944-45 and also the 12th appeal relating to the assessment for the assessment year