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1 - 10 of 11 (0.51 seconds)The Income Tax Act, 1961
Section 206C in The Income Tax Act, 1961 [Entire Act]
The Finance Act, 2018
The Asst. Commissioner Of Income-Tax vs Shri Hiromi Hirose, Japan Broadcasting ... on 31 August, 2006
The Hon'ble High Court was of the view that the time limit for completing
the assessment as per Section 153(1)(a) is two years from the end of the
assessment year in which the income was first assessable which was
considered as reasonable period for passing the order U/s 201(1)/201(1A)
of the Act. The Hon'ble High Court has turned down the contention of
limitation provided U/s 147/148 of the Act and hence, it was observed that
three years would be a reasonable period as prescribed by Section 153 for
completion of proceedings. However, since the Tribunal in a series of
decisions had taken a view that the period within which the order U/s
201(1)/201(1A) shall be passed would be four years and therefore, the
Hon'ble High Court has refrained from disturbing the view taken by this
Tribunal. Following the said decision, the Hon'ble Delhi High Court in a
subsequent decision in the case of Vodafone Essar Mobile Services Ltd. Vs
Union of India & ors. (supra) has reiterated the view taken in the case of
CIT Vs NHK Japan Broadcasting (supra).
Vodafone Essar Mobile Services Limited ... vs Union Of India & Ors on 9 March, 2016
The Hon'ble High Court was of the view that the time limit for completing
the assessment as per Section 153(1)(a) is two years from the end of the
assessment year in which the income was first assessable which was
considered as reasonable period for passing the order U/s 201(1)/201(1A)
of the Act. The Hon'ble High Court has turned down the contention of
limitation provided U/s 147/148 of the Act and hence, it was observed that
three years would be a reasonable period as prescribed by Section 153 for
completion of proceedings. However, since the Tribunal in a series of
decisions had taken a view that the period within which the order U/s
201(1)/201(1A) shall be passed would be four years and therefore, the
Hon'ble High Court has refrained from disturbing the view taken by this
Tribunal. Following the said decision, the Hon'ble Delhi High Court in a
subsequent decision in the case of Vodafone Essar Mobile Services Ltd. Vs
Union of India & ors. (supra) has reiterated the view taken in the case of
CIT Vs NHK Japan Broadcasting (supra).
Finance Act, 2019
Commissioner Of Income Tax vs Bharat Hotels Ltd. on 30 June, 2016
Thus, four years time period was considered as reasonable period for
passing the order U/s 201(1)/201(1A) of the Act. We find that the similar
view has been taken by the Hon'ble Andhra Pradesh High Court in the case
of CIT Vs. U.B. Electronics Instruments Ltd. (2015) 371 ITR 314 (AP) as
well as by the Hon'ble Kerala High Court in the case of CIT(TDS) & Anr. Vs
Bharat Hotels Limited (2016) 384 ITR 77 (Karn.). The Hon'ble Karnataka
High Court has dealt this issue in para 23 to 27 as under:
Commissioner Of Income Tax Ii, ... vs M/S.U.B. Electronic Instruments Ltd., ... on 12 November, 2014
Thus, four years time period was considered as reasonable period for
passing the order U/s 201(1)/201(1A) of the Act. We find that the similar
view has been taken by the Hon'ble Andhra Pradesh High Court in the case
of CIT Vs. U.B. Electronics Instruments Ltd. (2015) 371 ITR 314 (AP) as
well as by the Hon'ble Kerala High Court in the case of CIT(TDS) & Anr. Vs
Bharat Hotels Limited (2016) 384 ITR 77 (Karn.). The Hon'ble Karnataka
High Court has dealt this issue in para 23 to 27 as under: