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2018 (5) TMI 1689 - AT - Income TaxValidity of reassessment proceedings u/s 147 - validity of notice u/s 148 - assessment barred by limitation - assessment in wrong hands - Held that:- The reopening is not permissible in the case of the assessee when the limitation was not available even on the date when the assessment order - the limitation is saved if the same was available on the date when the assessment order was passed in the wrong hands and, therefore, the subsequent time period consumed in the proceedings before the first appellate authority and thereafter will not affect the power of the AO for reopening of the assessment. - Decided in favor of assessee.
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