Meaning of “After expiry of four years from end of relevant assessment year”

Case Name : Fateh chand charitable trust vs. CIT

Citation : [2013] 36 taxmann.Com 67/219 taxman 172/357 ITR 604 (all.)

Court : Allahabad high court

Section : 147

Meaning : The phrase used in the proviso is ‘after the expiry of four years from the end of the relevant assessment year’. Clearly it postulates that the starting up of four years period will be from the end of the assessment year, i.E., For the assessment year 2006-07, the assessment year will expire on 31-3-2007 and four years period from that date expires on 31-3-2011.

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