https://www.taxtmi.com/caselaws?id=246883 The High Court dismissed the appeal against the Tribunal's decision regarding the validity of the assessment order under Section 143 read with Section 147 of the Income Tax Act for the assessment year 2005-06. The Court found that the reasons for reopening the assessment did not correspond with the income ultimately assessed. The Court determined that Explanation-3 to Section 147, with retrospective effect, was not applicable in this case. Citing decisions by various High Courts, the Court clarified that Explanation-3 only applies to issues existing at the time of the original assessment, not to new issues arising later. The Court upheld the Tribunal's decision based on the consistent view of other High Courts and dismissed the appeal. en-us Wed, 12 Mar 2014 00:00:00 +0530 Fri, 25 Apr 2014 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246883 The High Court dismissed the appeal against the Tribunal's decision regarding the validity of the assessment order under Section 143 read with Section 147 of the Income Tax Act for the assessment year 2005-06. The Court found that the reasons for reopening the assessment did not correspond with the income ultimately assessed. The Court determined that Explanation-3 to Section 147, with retrospective effect, was not applicable in this case. Citing decisions by various High Courts, the Court clarified that Explanation-3 only applies to issues existing at the time of the original assessment, not to new issues arising later. The Court upheld the Tribunal's decision based on the consistent view of other High Courts and dismissed the appeal. Case-Laws Income Tax Wed, 12 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246883