Extended
time-limit of 6 yrs under section 149(1)(b) requires data for prima facie computation of income
escaping assessment.
The
High Court held as under:
1) Extended time-limit
of 6 years under section 149(1)(b)to initiate proceedings to bring to tax
income escaping assessment cannot be availed by AO without getting hold of data
which prima facie supports
computation of quantum of income
escaping assessment above one lakh rupee;
2) The Assessing
Officers may be handicapped in such cases but there are sufficient provisions
in the Act to get hold of the said data before proceedings are initiated or
reasons are recorded;
3) The AO must obtain
such data for relevant assessment year and cannot even use data of subsequent
or other assessment years as figures for every year will alter or change.
