Supreme Court · 1987 INSC 137 · Decided 28 April 1987

R.K.UPADHYAYA v. Shanabhai P. Patel

Court
Supreme Court of India
Citation
1987 INSC 137 · [1987] 3 S.C.R. 42
Case number
CIVIL APPEAL No. 544/1975
Decided
28 April 1987
Bench
RANGANATH MISRA, G.L. OZA (2-judge bench)
Outcome
Appeal(s) allowed
Case type
Civil
Acts & sections cited
Income Tax Act Section 147, 148, 149, 147(b)

Headnote

v. SHANABHAI P. PATEL APRIL 28, 1987 [RANGANATH MISRA AND G.L. OZA, jJ.] Income Tax Act, 1961/Income Tax Act, 1922-Sections 147, 148 and 149/Section. 34--Notice for reassessment-Issuance of-'!Ssue of notice' and 'service of notice'-Distinction between-Reassessment not to be made until Income Tax Act, 1961 for the assessment year 1965-66. The High Court quashed the notice holding that the action of the Income Tax Otlicer was barred by limitation prescribed by the Act. Allowing the appeal of the Revenue, HELD: I. The scheme of the 1961 Act so far as notice for reas­ sessment

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