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The High Court held that the Assessing Officer is not restricted from issuing a fresh notice u/s 148 of the Income Tax Act, even after filing of earlier reassessment proceedings, provided it is within the limitation period. In the present case, the petitioner had not disclosed income truthfully before the Settlement Commission. This gave the Assessing Officer a new cause of action to initiate fresh proceedings u/s 148 based on the Commission's observations of non-disclosure. The objections raised against the fresh reassessment were without basis. The Court recalled its interim order and directed the respondents to continue and pass the final assessment order based on the reassessment proceedings initiated under the fresh notice, following due process as per law.
The High Court held that the Assessing Officer is not restricted from issuing a fresh notice u/s 148 of the Income Tax Act, even after filing of earlier reassessment proceedings, provided it is within the limitation period. In the present case, the petitioner had not disclosed income truthfully before the Settlement Commission. This gave the Assessing Officer a new cause of action to initiate fresh proceedings u/s 148 based on the Commission's observations of non-disclosure. The objections raised against the fresh reassessment were without basis. The Court recalled its interim order and directed the respondents to continue and pass the final assessment order based on the reassessment proceedings initiated under the fresh notice, following due process as per law.
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