https://www.taxtmi.com/caselaws?id=262552 The court dismissed the Special Civil Application, ruling that the petitioner could not challenge the notice under Section 148 of the Income Tax Act at this stage. The court found the challenge to be malafide and an afterthought due to the petitioner's participation in the reassessment proceedings without objection and the subsequent issuance of a show-cause notice under Section 263 of the Act. The principle of Rule of Consistency was deemed inapplicable, and the petition was dismissed with the rule being discharged. en-us Wed, 29 Apr 2015 00:00:00 +0530 Thu, 13 Aug 2015 07:01:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262552 The court dismissed the Special Civil Application, ruling that the petitioner could not challenge the notice under Section 148 of the Income Tax Act at this stage. The court found the challenge to be malafide and an afterthought due to the petitioner's participation in the reassessment proceedings without objection and the subsequent issuance of a show-cause notice under Section 263 of the Act. The principle of Rule of Consistency was deemed inapplicable, and the petition was dismissed with the rule being discharged. Case-Laws Income Tax Wed, 29 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262552