THE COMMISSIONER OF INCOME TAX AND ANR vs. M/S GOLDSTONE CEMENTS LTD.

Bench: HONOURABLE THE CHIEF JUSTICE,HONOURABLE MRS. JUSTICE SUSMITA PHUKAN KHAUND

reopening u/s. 147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact