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2006 (9) TMI 174 - HC - Income Tax
Notice issued u/s 148 proposing to reassess the income but no reason were recorded – reasons given thereafter on request of petitioner were unconnected with the reasons stated in the notice issued u/s 142 – no regular assessment in stipulated time – no allegation of escapement - return filed had already become final and that finality could not be disturbed even in a proceeding u/s 147 - held that AO had no jurisdiction to proceed with the items covered in the notices issued u/s 143(2) and 142