https://www.taxtmi.com/caselaws?id=62255 The Tribunal held that the reopening of the assessment under Section 147(a) was not justified as the conveyance deed was already available in the records of the Assessing Officer. The Tribunal concluded that the case fell within the ratio of the Supreme Court's decision in Gemini Leather Stores vs. ITO, and hence, the reopening of the assessment could not be sustained. Additionally, even if the reopening could be justified under Section 147(b) based on audit party objections, the limitation for such action had expired. Therefore, the reassessment proceedings initiated by the ITO failed, and the appeal was allowed, leading to the cancellation of the reassessment proceedings. en-us Fri, 23 Sep 1994 00:00:00 +0530 Tue, 18 Jan 2011 18:09:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62255 The Tribunal held that the reopening of the assessment under Section 147(a) was not justified as the conveyance deed was already available in the records of the Assessing Officer. The Tribunal concluded that the case fell within the ratio of the Supreme Court's decision in Gemini Leather Stores vs. ITO, and hence, the reopening of the assessment could not be sustained. Additionally, even if the reopening could be justified under Section 147(b) based on audit party objections, the limitation for such action had expired. Therefore, the reassessment proceedings initiated by the ITO failed, and the appeal was allowed, leading to the cancellation of the reassessment proceedings. Case-Laws Income Tax Fri, 23 Sep 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62255