Reopeing of case

[S.C. WADHWA]

Dear Experts,

A notice recd u/s 148 for A.Y.2008-09 after the expiry of four years with a note that A.O. has taken permission from joint commissioner that it is a fit case for the issue of such notice, on 2.2.14. We give reply' return filed originally could be treated as return filed pursuant to the notice u/s 148 of the Act.'Notice u/s 142(1) recd but u/s 143(2) not recd till now which was to be recd upto 30.9.14 with in 6 months from the end of the year in which return was filed. Now my query is whether we should filed objection during the assessment is in process. Please give your expert opinion.

WADHWA

[DR.MARIAPPAN GOVINDARAJAN]

Please inform what is the financial year in this case.

[S.C. WADHWA]

Financial year 2007-08 i.e from 1.4.2007 to 31.03.2008.

AI Summary

Reopening assessments after limitation: whether to object when assessment proceeds without issuance of the regular assessment order. A reassessment notice was issued after the four year limitation with joint commissioner approval. The taxpayer requested that the original return be treated as filed pursuant to the reassessment notice. A summary inquiry notice was received but the regular assessment order has not been issued within the expected six month period. The core question is whether to file an objection while assessment proceedings continue in the absence of the regular assessment order.