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ITAT upheld the validity of reopening assessment under Section 147, rejecting the assessee's challenge to the Section 148 notice. The Tribunal found that since no regular assessment under Section 143(3) had previously been conducted, with the return only processed under Section 143(1), the notice issued with JCIT's authority after four years was procedurally valid per Section 151(2). However, regarding cartage expenses, the ITAT partially allowed the appeal by restricting the disallowance to 15% of the expenses, consistent with the CIT(A)'s order for A.Y. 2011-12 which involved identical factual circumstances.
ITAT upheld the validity of reopening assessment under Section 147, rejecting the assessee's challenge to the Section 148 notice. The Tribunal found that since no regular assessment under Section 143(3) had previously been conducted, with the return only processed under Section 143(1), the notice issued with JCIT's authority after four years was procedurally valid per Section 151(2). However, regarding cartage expenses, the ITAT partially allowed the appeal by restricting the disallowance to 15% of the expenses, consistent with the CIT(A)'s order for A.Y. 2011-12 which involved identical factual circumstances.
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