HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD
In the result, both the appeals filed by assessee are allowed
ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68
reassessment proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action for reopening can be taken beyond four years unless there is a failure