JAMYANG KHYENTSE YESHI,KANGRA, HIMACHAL PRADESH vs. ACIT, DCIT, C.R. BUILDING, CHANDIGARH
The appeal of the assessee is partly allowed
ITA 604/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh17 Nov 2025AY 2013-14
Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):
For Appellant: Shri Nitin Kanwar, Advocate (Virtual)For Respondent: Shri Prem Singh, Addl. CIT, Sr. DR
Section 133(6)Section 147Section 148Section 69A
147 to 153, in relation to both reopening u/s 148 and making reassessment, thus reassessment was bad in law and in procedure.
3. That notice u/s 148 dated 31.03.2021 was issued on 01.04.2021, therefore it would be governed by the re-assessment regime which came into effect on 01.04.2021, thus, assessment is not according to new procedure established