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ADVANCE AN-8643/8644 Driver

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Any drivers for any computers. The Court in Bhatinda District supra held as follows: It is trite that if no period of limitation ADVANCE AN-8643/8644 been prescribed, statutory authority must exercise its jurisdiction within a reasonable period.

What, however, shall ADVANCE AN-8643/8644 the reasonable period would depend upon the nature of the statute, rights and liabilities thereunder and other relevant factors. Revisional jurisdiction, in our opinion, ADVANCE AN-8643/8644 ordinarily be exercised within a period of three years having regard to the purport in terms of the said Act.

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In any event, the same should not exceed the period of five years. The view of the High Court, thus, cannot be said to be ADVANCE AN-8643/8644.

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Reasonable period, keeping in view the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum ADVANCE AN-8643/8644 of limitation ADVANCE AN-8643/8644 for in Sub-section 6 of Section 11 of the Act is five years.

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Although, the context of the dispute was in respect of recording of a satisfaction note as to the initiation of proceedings against third parties under erstwhile Section BD of the Act which did not prescribe the period of limitation and left it ADVANCE AN-8643/8644 the discretion of the AO to decide on being satisfied that such proceedings were required to be initiated, the Court limited such discretion in the following terms: In the result, ADVANCE AN-8643/8644 hold that for the purpose of Section BD of the Act a satisfaction note is sine qua non and must be prepared by the assessing officer before he transmits the records to the other assessing officer who has jurisdiction over such other person.

The satisfaction note ADVANCE AN-8643/8644 be prepared at either of the following stages: An added ADVANCE AN-8643/8644 why the submission of the Revenue is unacceptable is that had the Parliament indeed intended to overrule or set aside the reasoning in NHK Japan suprait would have, like other instances and more specifically in the case of Section 1Abrought in a retrospective amendment, nullifying ADVANCE AN-8643/8644 precedent itself.

That it chose to bring Section 3 in the first instance in and later in fortifies the reasoning of the Court.

Accordingly, the issue is answered against the Revenue. It appears to the Court that the above decision settles the question whether to declare an Assessee ADVANCE AN-8643/8644 be an Assessee in default under Section of the Court could be initiated for a period earlier than four years prior to 31 st ADVANCE AN-8643/8644, Syali, the learned Senior Advocate for the Petitioners states that although the challenge in these petitions is also to the vires of the proviso to Section 3 of the Act as inserted by the Finance No.

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In other words what has been canvassed on behalf of the Petitioners is that the proviso to Section 3 of the Act has to be ADVANCE AN-8643/8644 consistent ADVANCE AN-8643/8644 the law explained by the Court in CIT vs. NHK Japan Broadcasting Corporation supra and should be held not to permit the Department to initiate proceedings for declaring Assessees to be Assessees in default for a period more than four years prior to ADVANCE AN-8643/8644 st March, Dileep Shivpuri, the learned Senior Standing Counsel for the Revenue, however, seeks to advance a different line of argument.

According to him the action taken by the Department was pursuant to a decision in CIT v.

Idea Cellular Ltd. It is stated that ADVANCE AN-8643/8644 is consequent upon the ADVANCE AN-8643/8644 decision that the Department issued the impugned notices to these Petitioners and that this was permissible in terms of Section 3 ii of the Act. The above submission of Mr. Shivpuri cannot be accepted if Section is perused carefully.

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