https://www.taxtmi.com/caselaws?id=188182 The High Court condoned a 215-day delay in re-filing the application. The court dismissed the Revenue's appeal challenging the validity of a notice issued under section 148 of the Income-tax Act for reopening the assessment, as the reassessment order adding a different sum was found unsustainable due to not aligning with the reasons to believe. The addition to income based on reasons to believe was also deemed unsustainable, leading to the dismissal of the appeal. The court clarified that Explanation 3 to section 147 cannot be used if additions do not align with the reasons for reopening the assessment. en-us Wed, 03 Feb 2016 00:00:00 +0530 Mon, 21 Nov 2016 14:32:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188182 The High Court condoned a 215-day delay in re-filing the application. The court dismissed the Revenue's appeal challenging the validity of a notice issued under section 148 of the Income-tax Act for reopening the assessment, as the reassessment order adding a different sum was found unsustainable due to not aligning with the reasons to believe. The addition to income based on reasons to believe was also deemed unsustainable, leading to the dismissal of the appeal. The court clarified that Explanation 3 to section 147 cannot be used if additions do not align with the reasons for reopening the assessment. Case-Laws Income Tax Wed, 03 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188182