147. In Rakesh Aggarwal v. Asstt. CIT

225 ITR 496High Court1997#1814 most cited

What is 147. In Rakesh Aggarwal v. Asstt. CIT authority for?

Under the amended Section 147, a reassessment notice issued under Section 148 is illegal if it is served more than four years after the end of the relevant assessment year, particularly when the original assessment was completed under Section 143(3), due to the proviso to Section 147.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

Rakesh Aggarwal v. Asstt. CIT · Rakesh Aggarwal 225 ITR 496 · Section 147 reassessment · Section 148 notice · amended Section 147 · proviso to Section 147 · four year limitation · original assessment Section 143(3) · reassessment legality · Delhi High Court

Sections most often in play

Section 131Section 132Section 133(6)Section 139Section 142(1)Section 143(3)Section 147Section 148

Issues it is cited on

section 147(1)section 11(4)section 4asection 147(b)section 31(3)section 164(2)section 11(6)advancement of general public utilitysection 153(3)section 139(3)section 44bbsection 44b

Judgments citing 147. In Rakesh Aggarwal v. Asstt. CIT

M/S. INDIA EXPOSITION MART LTD.,NEW DELHI vs. DCIT, NEW DELHI

ITA 1079/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Aug 2025AY 2009-10

Bench: Shri Mahavir Singhshri Kuldip Singh & Shri Anadee Nath Misshra, Accountnat Member Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 139(1)Section 147Section 148

…wed in that angle power to reopen asstt. is much wider under the amended provision and can be exercised even after assessee has disclosed fully and truly all the material facts, so similar view were the conclusion of this Court (Delhi) in 142 CTE (Delhi) 272, 225 ITR 496. Further, as per clause (b) of Explanation to section 147 even if the assessment has not been made in terms of section 143(3) and only intimation has been sent to the assessee in pursuance of return filed by him, a reopening by issue of notice u/s 148 can be made in accordance with the provisions of section 147. (Ranchi Club Ltd. Vs CIT 214 ITR 6…

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

ITA 514/CHANDI/2023[2012-2013]Status: DisposedITAT Chandigarh02 Jan 2025AY 2012-2013

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT-DR
Section 127Section 132Section 143(3)Section 147Section 148Section 148(2)Section 153Section 153A

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH ‘B’ CHANDIGARH BEFORE: SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER, आयकर अपील सं./ ITA No. 514/CHD/2023 "नधा"रण वष" / Assessment Year : 2012-13 M/s S.P.Singla Construction Versus The DCIT, Pvt.Ltd., Flat No. 1006-1007, Central Circle-1, 10th Floor, Pearls Best Height-1, Chandigarh. Netaji Subhash Place, Pitampura, Delhi. "थायी लेखा सं./PAN /TAN No: AACCS5773B अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Ashwani Kumar, CA Shri Aditya Kumar, CA Ms. M…

BEST REALTRECH INDIA P.LTD,NEW DELHI vs. ITO, WARD-4(3), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 390/DEL/2020[2011-12]Status: DisposedITAT Delhi27 Dec 2024AY 2011-12

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanm/S Best Realtrech Income Tax Officer, (India) Pvt. Ltd., Ward-4(3), New Delhi H-8, First Floor, Vs. Best Plaza, Netaji Subhash Place, Pitampura, Delhi-110034 Pan:Aadcb1848D (Appellant) (Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 68

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

MANIPAL FINANCIAL SERVICES,CHENNAI vs. ITO, BUSINESS WARD XV(4), CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 947/CHNY/2024[2005-06]Status: DisposedITAT Chennai12 Sept 2024AY 2005-06

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.:947/Chny/2024 िनधा"रण वष"/Assessment Year:2005-06 Manipal Financial Services, The Income Tax Officer, 328, Plaza Centre, Business Ward Xv(4), Vs. 129 Gn Chetty Road, Chennai. Chennai – 600 006. Pan: Aakfm 7449R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms. R.Anita, Jcit सुनवाई क" तारीख/Date Of Hearing : 10.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 12.09.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi In Order No.Itba/Nfac/S/250/2023-24/ 1061661390(1) Dated 28.02.2024. The Assessment Was Framed By The Income Tax Officer, Business Ward Xv(4), Chennai For The Assessment Year 2005-06 U/S.147 R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 25.03.2013. 2. The First Issue In This Appeal Of Assessee Is As Regards To The Order Of Cit(A)-Nfac Confirming The Action Of The Ao In Assuming Jurisdiction U/S.147 Of The Act & Consequently Confirmed The Reassessment Order.

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Ms. R.Anita, JCIT
Section 143(1)Section 143(3)Section 147Section 148Section 47

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

BIG BOSS FOODS PVT. LTD.,BURDWAN vs. ACIT, CIR. 1, BURDWAN

In the result, the appeal filed by the assessee is allowed

ITA 398/KOL/2024[2013-14]Status: DisposedITAT Kolkata11 Sept 2024AY 2013-14

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 143(3)Section 147Section 148Section 151(1)Section 250Section 40

…आयकर अपीलीय अधिकरण कोलकाता 'बी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA श्री राजेश कुमार, लेखा सदस्य एवं श्री प्रदीप कुमार चौबे, न्याधयक सदस्य के समक्ष Before SRI RAJESH KUMAR, ACCOUNTANT MEMBER & PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER I.T.A. No.: 398/KOL/2024 Assessment Year: 2013-14 Big Boss Foods Pvt. Ltd............................................................Appellant [PAN: AABCB 1001 E] Vs. ACIT, Cir.-1, Burdwan...........................................................Respondent Appearances: Assessee represented by: P.J. Bhide, AR. Department represented by: P.P.…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, TIRUNELVELI, TIRUNELVELI vs. MS.AARTHI SCANS, KOVILPATTI

In the result, the appeal filed by the Revenue is dismissed

ITA 75/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 May 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri P. Sajit Kumar, JCITFor Respondent: Shri Vijay Kumar, CA
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1638/CHNY/2023[2018-19]Status: DisposedITAT Chennai27 Mar 2024AY 2018-19

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1637/CHNY/2023[2017-18]Status: DisposedITAT Chennai27 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1636/CHNY/2023[2016-17]Status: DisposedITAT Chennai27 Mar 2024AY 2016-17

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1635/CHNY/2023[2015-16]Status: DisposedITAT Chennai27 Mar 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1634/CHNY/2023[2014-15]Status: DisposedITAT Chennai27 Mar 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1633/CHNY/2023[2013-14]Status: DisposedITAT Chennai27 Mar 2024AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1632/CHNY/2023[2012-13]Status: DisposedITAT Chennai27 Mar 2024AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…effect from 1-4-1989. The new section 147 has made a radical departure from the original section 147 inasmuch as clauses (a) and (b) of the original section 147 have been deleted and a new proviso added to section 147. In Rakesh Aggarwal v. Asstt. CIT [1997] 225 ITR 496/[1996] 87 Taxman 306, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147 and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be…

STAR PLASTICS,CHENNAI vs. DCIT, CHENNAUI

In the result, the appeal filed by the assessee is allowed

ITA 707/CHNY/2023[2011-12]Status: DisposedITAT Chennai22 Mar 2024AY 2011-12

Bench: SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Ms.N.V. Lakshmi, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 209/CHNY/2020[2010-11]Status: DisposedITAT Chennai23 Feb 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 208/CHNY/2020[2009-10]Status: DisposedITAT Chennai23 Feb 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 207/CHNY/2020[2008-09]Status: DisposedITAT Chennai23 Feb 2024AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

DCIT CENTRAL CIRCLE-3(1), CHENNAI vs. SANTHA BUILD TECH INIDA PRIVATE LIMITED, EKKATUTHANGAL

In the result, the appeal filed by the Revenue is dismissed

ITA 573/CHNY/2023[2013-14]Status: DisposedITAT Chennai08 Nov 2023AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri AR.V. Sreenivasan, Addl.CITFor Respondent: None
Section 143(3)Section 147Section 148Section 194A

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh Aggarwal v. Asst. CIT (1997] 225 ITR 496, the Delhi High Court held that in view of the proviso to Section 147 notice for reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued m…

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