19 December 2010
Exp. IV of 245A(b) says that proceeding for any A.Y shall be deemed to have commenced from 1st day of A.Y unless it is a case of clause (i) or (iv) of proviso or of clause (iiia) of explana tion. That means assessee need not to wait for issue of 143(2) notice or Show Cause notice of 144 for filing application u/s 245C (because generally proceeding commenced from the date of issue of such notice, But as per exp interpritation he need not to wait for issue of such notice). Am i correct? If not then why?
20 December 2010
If there is neither a notice of 143(3), 144 or nor escape assessment notice then where is the question for 245(c) settlement. If dept is not going to open your assessment where assessee himself going to open the assessment by filling 245(c)
CAclubindia
