MAHANT PANDEY,ROHTAS vs. NFAC, DELHI
In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
ITA 182/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18
Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)
reassessment proceedings are bad in law in the absence of reasons recorded for issuing a reopening notice under section 148 of the Act being furnished to the assessee when sought for. It is axiomatic that power to reopen a completed assessment under the Act is an exceptional power and whenever revenue seeks to exercise such power, they must strictly comply