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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Ranbaxy Laboratories Ltd. v. CIT
336 ITR 136 · 2011 · High Court
398
citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Lokhandwala Kataria Construction (Pvt) Ltd, Mumbai vs. Dy CIT CC 8(3), Mumbai

In the result, appeal by the assessee for assessment year 2011-12 is partly allowed

ITA 1345/MUM/2020[2010-11]Status: DisposedITAT Mumbai12 Sept 2022AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Dhaval ShahFor Respondent: Shri Mehul Jain
Section 143(1)Section 148Section 250Section 7

should be considered as return filed in response to the notice issued under section 148 of the Act. During the course of reassessment proceedings, assessee submitted that the construction cost includes purchase of building material such as steel, cement, etc. made by the assessee. The assessee submitted documents such ... no.1345/Mum./2020 from the Investigation Wing, Mumbai that assessee is the beneficiary of bogus purchases from an entity viz. M/s Sai International Impex, reassessment proceedings in the case of the assessee were initiated. Further, notices issued under section 133(6) by the AO to the aforesaid entity were also returned

Lokhandwala Kataria Construction (Pvt) Ltd, Mumbai vs. Dy CIT CC 8(3), Mumbai

In the result, appeal by the assessee for assessment year 2011-12 is partly allowed

ITA 1344/MUM/2020[2011-12]Status: DisposedITAT Mumbai12 Sept 2022AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Dhaval ShahFor Respondent: Shri Mehul Jain
Section 143(1)Section 148Section 250Section 7

should be considered as return filed in response to the notice issued under section 148 of the Act. During the course of reassessment proceedings, assessee submitted that the construction cost includes purchase of building material such as steel, cement, etc. made by the assessee. The assessee submitted documents such ... no.1345/Mum./2020 from the Investigation Wing, Mumbai that assessee is the beneficiary of bogus purchases from an entity viz. M/s Sai International Impex, reassessment proceedings in the case of the assessee were initiated. Further, notices issued under section 133(6) by the AO to the aforesaid entity were also returned

Tech Mahindra Ltd., Mumbai vs. ACIT, Cir.-2(3)(1), Mumbai

Appeal is allowed

ITA 3213/MUM/2019[2012-13]Status: DisposedITAT Mumbai12 Sept 2022AY 2012-13
For Appellant: Shri J.D. MistryFor Respondent: Shri Murali Mohan
Section 143(3)Section 147Section 263

survive. 3. We have perused the abovesaid order of the Tribunal passed in the case of Appellant/Assessee for the Assessment Year 2012- 13. The reassessment proceedings have been struck down as being invalid. Since the order dated 31.12.2018 passed under Section 147 read with Section

M/S. Arshiya Rail Infrastucture Ltd., Mumbai vs. Dy CIT - CC-6(4), Mumbai

In the result appeal by the assessee is allowed

ITA 574/MUM/2021[2012-13]Status: DisposedITAT Mumbai09 Sept 2022AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Piyush Chhajed a/wFor Respondent: Shri Mehul Jain
Section 115Section 139(1)Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 14ASection 153C

scrutiny assessment proceedings under section 143 (3) of the Act. 5. Thereafter, on 27/03/2019, notice under section 148 of the Act was issued and reassessment proceedings in the case of the assessee were initiated on the basis of information received from DDIT (Investigation), Kolkata regarding certain paper/shell companies i.e. Silverson ... year under consideration. 7. On the other hand, learned Departmental Representative by vehemently relying upon the orders passed by the lower authorities submitted that reassessment proceedings were initiated on the basis of specific information received from DDIT (Investigation), Kolkata and thus, same have been validity initiated. 8. We have considered

ADIT (It)-3(2), Mumbai vs. M/S. Nagase & Company Ltd., Mumbai

In the result, appeal by the Revenue is dismissed

ITA 2312/MUM/2007[2003-2004]Status: DisposedITAT Mumbai09 Sept 2022AY 2003-2004

Bench: Shri Prashant Maharashi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri C.T. Mathews
Section 143(3)Section 234BSection 250

assessment year under consideration i.e. 2001–02, the original return of income was filed by the assessee on 25/10/2001 declaring nil income. Subsequently, the reassessment proceedings were initiated under section 147 of the Act on the basis of documents found during the course of survey action under section 133A

M/S. Nagase & Company Ltd., Mumbai vs. ADIT (I.T) - RG.-3(2), Mumbai

In the result, appeal by the Revenue is dismissed

ITA 1805/MUM/2007[2003-2004]Status: DisposedITAT Mumbai09 Sept 2022AY 2003-2004

Bench: Shri Prashant Maharashi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri C.T. Mathews
Section 143(3)Section 234BSection 250

assessment year under consideration i.e. 2001–02, the original return of income was filed by the assessee on 25/10/2001 declaring nil income. Subsequently, the reassessment proceedings were initiated under section 147 of the Act on the basis of documents found during the course of survey action under section 133A

M/S. Nagase & Company Ltd., Mumbai vs. ADIT (I.T) - RG.-3(2), Mumbai

In the result, appeal by the Revenue is dismissed

ITA 1803/MUM/2007[2001-2002]Status: DisposedITAT Mumbai09 Sept 2022AY 2001-2002

Bench: Shri Prashant Maharashi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri C.T. Mathews
Section 143(3)Section 234BSection 250

assessment year under consideration i.e. 2001–02, the original return of income was filed by the assessee on 25/10/2001 declaring nil income. Subsequently, the reassessment proceedings were initiated under section 147 of the Act on the basis of documents found during the course of survey action under section 133A

The ADIT(It)-3(2), Mumbai vs. M/.S Nagase & Company Ltd, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 343/MUM/2006[2001-2002]Status: DisposedITAT Mumbai09 Sept 2022AY 2001-2002

Bench: Shri Prashant Maharashi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri C.T. Mathews
Section 143(3)Section 234BSection 250

assessment year under consideration i.e. 2001–02, the original return of income was filed by the assessee on 25/10/2001 declaring nil income. Subsequently, the reassessment proceedings were initiated under section 147 of the Act on the basis of documents found during the course of survey action under section 133A

M/S. Nagase & Co. Ltd., Mumbai vs. CIT(A) Xxxiii, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 118/MUM/2006[2001-2002]Status: DisposedITAT Mumbai09 Sept 2022AY 2001-2002

Bench: Shri Prashant Maharashi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri C.T. Mathews
Section 143(3)Section 234BSection 250

assessment year under consideration i.e. 2001–02, the original return of income was filed by the assessee on 25/10/2001 declaring nil income. Subsequently, the reassessment proceedings were initiated under section 147 of the Act on the basis of documents found during the course of survey action under section 133A

Smt Kiran Anil Shah, Mumbai vs. Prin. Comm of Income Tax -27, Mumbai

In the result, the appeal of the assesse is allowed

ITA 686/MUM/2022[2012-13]Status: DisposedITAT Mumbai08 Sept 2022AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhsmt. Kiran Anil Shah Vs. Pcit-27, 3Rd Floor, B-14, Plot No. R. No. 401, 4Th Floor, 33/34, Yogakshema Chs Tower No. 6, Vashi Ltd, Nathpai Nagar, Railway Station Ghatkopar- East, Commercial Complex, Mumbai – 400 077 Vavhi, Navi Mumbai 400 703 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Anrps9911N Appellant .. Respondent

For Appellant: Vijay MehtaFor Respondent: Tejinder Pal Singh
Section 143(3)Section 148Section 263Section 40A(3)

cash withdrawal reflected in the bank account of the proprietary concern of the assessee as elaborated supra in this order. During the course of reassessment proceedings the assessee explained the credit reflected in her bank accounts with relevant supporting materials that same was on account of sale and purchase ... assessee and not made any addition on the basis of which the case of the assessee was reopened. During the course of reassessment proceedings the assessee has made detailed submission vide letter dated 02.12.2019 and letter dated 11.12.2019 in respect of cash withdrawal from Bank along with purchase details

DCIT Central Circle(1), Mumbai vs. Shri Kumar Rasiklal Mehta, Mumbai

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 439/MUM/2022[2006-07]Status: DisposedITAT Mumbai08 Sept 2022AY 2006-07

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhdcit, Cc-2(1) Vs. Shri Kumar Rasiklal Old Cgo Bldg, 804, Mehta, 8Th Floor, Mk Road, 602-603, Prasad Mumbai – 400020. Chambers,Opera House, Mumbai - 400004 Pan/Gir No. Aaopm3805D Appellant .. Respondent C.O. No. 87/Mum/2022 (Arising Out Of Ita 439/Mum/2022) (A.Y: 2006-07) Shri Kumar Rasikal Vs. Dcit, Cc-2(1) Mehta, Old Cgo Bldg, 804, 8Th 602-603, Prasad Floor, Mk Road, Chambers,Operahouse, Mumbai – 400020. Mumbai - 400004 Pan/Gir No. Aaopm3805D Appellant .. Respondent

For Appellant: Shri .Harsh Kapadia.ARFor Respondent: Shri. Tejinder Pal Singh.DR
Section 131Section 133ASection 143(3)Section 148

439/Mum/2022 & CO No. 87/Mum/2022 Shri Kumar Rasiklal Mehta, Mumbai. 10. The assessee has raised the cross objections in respect of validity of the reassessment proceedings and is not pressed. Since the revenue appeal is dismissed the CO raised by the assessee on validity of reassessment becomes academic and is left

DCIT Cent. Cir 8(1), Mumbai vs. Sopariwala Exports Pvt. Ltd, Mumbai

ITA 1770/MUM/2021[2013-14]Status: DisposedITAT Mumbai08 Sept 2022AY 2013-14
For Appellant: Shri Siddharth KothariFor Respondent: Shri B.K. Bagchi
Section 143(3)Section 147

dated 26.02.2016, assessment under Section 143(3) of the Act was framed on the Assessee at income of INR 43,50,64,350/-. Thereafter, reassessment proceedings were initiated and order under Section 147 read with Section 143(3) of the Act was passed on 20.12.2019 making a disallowance

Sureaksha DB Realty, Mumbai vs. Deputy Commissioner of Income Tax 30(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 482/MUM/2018[2011-12]Status: DisposedITAT Mumbai08 Sept 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Suraksha Db Realty The Dy. Commissioner Of Behind Orchid Suburbia, Ground Income-Tax 30(3), Floor, Off; Link Road, Kandivali Room No.601, C-13, Vs. 6Th Floor, Bkc, (West), Mumbai-400 067 Mumbai-400 051 (Appellant) (Respondent) Pan No. Abofs0694R Assessee By : Shri Vijay Mehta, Ar Department By : Shri Op Sharma, Cit Dr

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri OP Sharma, CIT DR
Section 139(1)Section 143(3)Section 148Section 69CSection 80

versus Cheil communications India private limited (2013) 354 ITR 549 (del). In that particular case the learned assessing officer initiated reassessment proceedings with respect to an escapement of income of Rs 4 lakhs. In the assessment the addition of ₹ 4 lakhs were paid and also apart from that another addition

Faith Finsock P. Ltd., Mumbai vs. ITO - 12(2)(1), Mumbai

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1916/MUM/2020[2011-12]Status: DisposedITAT Mumbai06 Sept 2022AY 2011-12

Bench: Shri Sandeep Singh Karhail & Shri Gagan Goyalfaith Finstock Pvt. Ltd. 214, Linkway Estate Premises Chs Ltd. Chincholi Bunder, Malad (West), Mumbai-400064 Pan: Aaacf7046E ...... Appellant Vs. Ito-12(2)(1), Aayakar Bhavan, M.K. Road, Mumbai-400020. ..... Respondent Appellant By : None Respondent By : Ms. Kavita Kaushik Date Of Hearing : 09/06/2022 Date Of Pronouncement : 06/09/2022 Order Per Gagan Goyal, A.M:

For Appellant: NoneFor Respondent: Ms. Kavita Kaushik
Section 132Section 143(3)Section 147Section 148Section 234B

Faith Finstock Pvt. Ltd. “1. That the learned CIT (A), Mumbai has grossly erred both in law and on facts in confirming the reassessment proceedings and also framing the assessment under section 143(3)/147 of the Act determining the income of the assessee at an income of Rs.40 ... Rs.69,879/-. 2. That the learned CIT (A) has grossly erred both in law and on facts in failing to appreciate that initiating the reassessment proceedings by issuing a notice under section 148 of the Act, without satisfying the statutory preconditions as envisaged under section

M/S Reliable Ball Bearing Stores, Mumbai vs. ITO 20 (3)91), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 8026/MUM/2019[2009-10]Status: DisposedITAT Mumbai06 Sept 2022AY 2009-10
Section 133(6)Section 143(1)Section 143(3)Section 147

supplier had been treated as tainted dealer in its website. The validity of reopening is not in challenge before us. In the course of reassessment proceedings, the ld. AO sought to verify the veracity of purchases made by the assessee from M/s Nina Enterprises. The assessee furnished all the details ... that were called for by the ld. AO in the reassessment proceedings. Later a notice u/s 133(6) of the Act was issued by the ld. AO to M/s Nina Enterprises seeking confirmation of transactions with the assessee. The ld. AO had duly observed in Page 2 of his order

The ACIT Cent. Cir -5(4), Mumbai vs. Shri Nitan Chhatwal, Mumbai

In the result, the both the appeals of the revenue are dismissed

ITA 2244/MUM/2021[2015-16]Status: DisposedITAT Mumbai02 Sept 2022AY 2015-16
Section 132Section 139(1)Section 143(3)Section 153ASection 68

first proviso. It also means that only one assessment will be made under the aforesaid provisions as the two proceedings i.e. assessment or reassessment proceedings and proceedings under this provision merge into one. If assessment made under sub-section (1) is annulled in appeal or other legal proceedings, then ... placing reliance on the judgment of SC in the case of Rajesh Jhaveri (supra) held that the assessing officer was barred from initiating reassessment proceedings under section 147 when the time for issuance of notice under section 143(2) had not expired. However, taken a different view in the case

ACIT Cent. Cir -5(4), Mumbai vs. Shri Nitan Chhatwal, Mumbai

In the result, the both the appeals of the revenue are dismissed

ITA 2243/MUM/2021[2013-14]Status: DisposedITAT Mumbai02 Sept 2022AY 2013-14
Section 132Section 139(1)Section 143(3)Section 153ASection 68

first proviso. It also means that only one assessment will be made under the aforesaid provisions as the two proceedings i.e. assessment or reassessment proceedings and proceedings under this provision merge into one. If assessment made under sub-section (1) is annulled in appeal or other legal proceedings, then ... placing reliance on the judgment of SC in the case of Rajesh Jhaveri (supra) held that the assessing officer was barred from initiating reassessment proceedings under section 147 when the time for issuance of notice under section 143(2) had not expired. However, taken a different view in the case

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1050/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 Sept 2022AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

section 153A stand abated cannot be accepted. Similarly on annulment of assessment made under section 153A(1) what stands revived is the pending assessment / reassessment proceedings which stood abated as per section 153A(1). "Once it is held that the assessment has attained finality, then the Assessing Officer while passing

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1049/MUM/2019[2013-14]Status: DisposedITAT Mumbai02 Sept 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

section 153A stand abated cannot be accepted. Similarly on annulment of assessment made under section 153A(1) what stands revived is the pending assessment / reassessment proceedings which stood abated as per section 153A(1). "Once it is held that the assessment has attained finality, then the Assessing Officer while passing

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1048/MUM/2019[2012-13]Status: DisposedITAT Mumbai02 Sept 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

section 153A stand abated cannot be accepted. Similarly on annulment of assessment made under section 153A(1) what stands revived is the pending assessment / reassessment proceedings which stood abated as per section 153A(1). "Once it is held that the assessment has attained finality, then the Assessing Officer while passing