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of <h1>SLP dismissed; assessing officer had jurisdiction to reopen 2020-21 assessment as first notice valid under 5th and 6th provisos</h1> <h3>Chandra Shekhar Versus Principal Commissioner of Income Tax 1 & Anr.</h3> SC dismissed the Special Leave Petition, upholding the HC's finding that the assessing officer had jurisdiction to reopen assessment for 2020-21 because ... Reopening of assessment u/s 147 - AO has jurisdiction to undertake assessment for the year 2020-21 before 01.04.2024 or not? - HC [2025 (4) TMI 1490 - PATA HIGH COURT] held that there was no occasion for the Revenue to issue notice on 22.04.2024, if the petitioner’s contention in reply to the notice dated 31.03.2024, in particularly, therefore, proceedings have been initiated by issuing notice on 28.03.2024. Combined reading of 5th and 6th Proviso, it is crystal clear that delay is required to be taken note of with reference to notice. In the present case notice means first notice issued on 28.03.2024 and it is within the time-limit stipulated and AO has jurisdiction. Present writ petition is pre-mature HELD THAT:- We do not find good ground to interfere with the impugned judgment and order of the High Court. Hence, the Special Leave Petition is dismissed. 'Delay condoned.' The Court recorded that the petition was 'Heard.' It found no basis to disturb the 'impugned judgment and order of the High Court' and therefore the 'Special Leave Petition is dismissed.' The order contains no substantive re-evaluation of the High Court's findings and rests on the conclusion that there is 'no good ground to interfere.' All pending application(s), if any, were directed to 'stand disposed of.'
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