S. 271D period of Limitation to be reckoned from the date of First show cause notice irrespective of who issued it

HIGH COURT OF RAJASTHAN Commissioner of Income-tax, Udaipur Versus Jitendra Singh Rathore D.B. IT Appeal No. 90 of 2007 JANUARY  10, 2013 ORDER Arun Bhansali, J. This appeal under Section 260-A of the Income Tax Act, 1961 (‘the Act’) has been preferred by the Revenue against the judgment dated 22.09.2006 passed by the Income Tax Appellate Tribunal, Jodhpur Bench, Jodhpur (‘the Tribunal’) relating to the assessment year 2001-02. 2. The appeal was admitted on the following question of law:- “Whether on the facts and in the circumstances of the case...