Supreme Court of India

Sahara India (firm), Lucknow v. Commissioner of Income Tax, Central-i & Anr.

Neutral citation
Reported as [2008] 6 S.C.R. 427
Decided 11 April 2008

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

8 Supreme Court benches have cited this judgment.

What the Court ordered

We hold that the law on the subject, clarified by us, will apply prospectively B and it will not be open to the appellants to urge before the Appellate Authority that the extended period of limitation under Explanation 1 (iii) to Section 153 (3) of the Act was not available to the Assessing Officer because of an invalid order under Section 142 (2A) of the Act.

Judgment, page 29

From the headnote

Income tax Act, 1961 - s. 142(2A) - Special audit of accounts - Pre-decisional hearing - Requirement of - Held: Even in absence of express provision for affording or barring an opportunity of pre-decisional hearing to assessee, the requirement of observance of principles of natural justice to be read into s. 142(2A) since the order entails civil consequences - It would apply prospectively - However, it 0 would be open to assessee to question the correctness of material gathered on basis of audit report. Principles of natural justice - Concept and applicability of - Held: Rules of 'natural

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