KAUSHIK INDUSTRIES (P) LIMITED,TINSUKIA vs. INCOME TAX OFFICER, WARD-1, TINSUKIA
In the result, appeal of the assessee is allowed
ITA 11/GTY/2022[2011-12]Status: DisposedITAT Guwahati09 Jun 2023AY 2011-12
Bench: Shri Sanjay Garg & Shri Girish Agrawal
For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri N. T. Sherpa, JCIT
Section 143(3)Section 147Section 147(1)Section 148Section 263
section 147 clearly expunges that if notice for reopening of assessment was issued on one aspect and in course of reassessment proceedings another aspect was discovered, reassessment order would be valid, only if, aspect which led to reopening of assessment continues to form part of the reassessed income. If after issuing a notice u/s. 148, Ld. AO accepts the contention