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2013 (11) TMI 1236 - AT - Income Tax
Reassessment proceedings - change in opinion - legality of continuation of reassessment as a consequence of issuance and service of notice u/s 148 - held that:- the assessee has duly participated in the proceedings which is a sufficient material having bearing on the legal grounds raised that challenge is to the application of the jurisdiction whereas the fundamental challenge to the assumption of jurisdiction is neither addressed nor contested and thus having pleaded the assessment to be treated as unsustainable in law is unwarranted. - Decided against the assessee.