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Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated 28.03.2022, which had become final. Therefore, there was no basis for initiating a subsequent re-assessment proceeding. The Court held that in the absence of any declaration annulling or setting aside the previous re-assessment order, the Assessing Authority lacked jurisdiction to issue the second re-assessment notice. Thus, the proceedings initiated through the notice dated 30.07.2022 were declared as without jurisdiction and nullity.
Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated 28.03.2022, which had become final. Therefore, there was no basis for initiating a subsequent re-assessment proceeding. The Court held that in the absence of any declaration annulling or setting aside the previous re-assessment order, the Assessing Authority lacked jurisdiction to issue the second re-assessment notice. Thus, the proceedings initiated through the notice dated 30.07.2022 were declared as without jurisdiction and nullity.
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