https://www.taxtmi.com/caselaws?id=264292 Reopening under the income-tax reassessment provisions was treated as invalid because the Transfer Pricing Officer reference was made after assessment proceedings had ended and no notice under section 143(2) was issued within limitation. The scheme governing arm's length price determination applies only during pending assessment proceedings, so a reference under section 92CA(1) made after the proceedings lapsed was void. As the reassessment was founded on that void reference, it could not supply the required reason to believe under section 147. The notice under section 148 was therefore without jurisdiction and the reassessment was quashed in favour of the assessee. en-us Wed, 20 May 2015 00:00:00 +0530 Sat, 19 Sep 2015 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264292 Reopening under the income-tax reassessment provisions was treated as invalid because the Transfer Pricing Officer reference was made after assessment proceedings had ended and no notice under section 143(2) was issued within limitation. The scheme governing arm's length price determination applies only during pending assessment proceedings, so a reference under section 92CA(1) made after the proceedings lapsed was void. As the reassessment was founded on that void reference, it could not supply the required reason to believe under section 147. The notice under section 148 was therefore without jurisdiction and the reassessment was quashed in favour of the assessee. Case-Laws Income Tax Wed, 20 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264292