Notice issued u/s.158BC(a) cannot be equated to a notice issued u/s.148 to reopen an assessment

HIGH COURT OF DELHI Shibani Dutta versus Commissioner of Income-tax IT Appeal No. 169 OF 2012 July 12, 2012 JUDGMENT R.V. Easwar, J. This is an appeal by the assessee under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’). By order dated 13.03.2012, the following substantial question of law was framed: – “Whether the Income Tax Appellate Tribunal is right in holding that the block assessment order passed on 30th July, 2002 is not barred by limitation as Section 129 read with proviso to Explanation 1 to Section 158 BE of th...