Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Reopening of assessment u/s 147 - Addition u/s 68 - An alleged non-compliance of summons issued in some other years cannot be reckoned as 'failure on the part of assessee' and that too in some other assessment year. An enquiry was made in relation to share application money recd. while framing regular assessment of AY 2009-10 and assessment was framed taking note of outcome of such enquiry. Hence, mere reproduction of statutory language of first proviso would not meet the requirement of law for extension of limitation period beyond 4 years. - AT
Reopening of assessment u/s 147 - Addition u/s 68 - An alleged non-compliance of summons issued in some other years cannot be reckoned as 'failure on the part of assessee' and that too in some other assessment year. An enquiry was made in relation to share application money recd. while framing regular assessment of AY 2009-10 and assessment was framed taking note of outcome of such enquiry. Hence, mere reproduction of statutory language of first proviso would not meet the requirement of law for extension of limitation period beyond 4 years. - AT
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