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The High Court considered the reopening of assessment u/s 147 with reference to section 144B, following a proceeding u/s 148A. The petitioner did not respond to the notice u/s 148A (b) and did not request documents as per section 144B. The Court noted that the assessment order was preceded by the section 148A proceeding, including notices u/s 148A (b) and (d). The disclosures in the assessment order were already provided in the section 148A notices. The Court held that the petitioner has an alternative remedy through appeal to address these issues. The petitioner can raise all points before the appellate authority, including requesting document disclosure, upon filing an appeal. The appellate authority can consider these requests after registering the appeal with condonation of any delay, as per the law.
The High Court considered the reopening of assessment u/s 147 with reference to section 144B, following a proceeding u/s 148A. The petitioner did not respond to the notice u/s 148A (b) and did not request documents as per section 144B. The Court noted that the assessment order was preceded by the section 148A proceeding, including notices u/s 148A (b) and (d). The disclosures in the assessment order were already provided in the section 148A notices. The Court held that the petitioner has an alternative remedy through appeal to address these issues. The petitioner can raise all points before the appellate authority, including requesting document disclosure, upon filing an appeal. The appellate authority can consider these requests after registering the appeal with condonation of any delay, as per the law.
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