https://www.taxtmi.com/caselaws?id=337042 Reopening of assessment under section 147 cannot be sustained solely because the assessing officer failed to issue a notice under section 143(2); such inaction does not extend the limitation period for reassessment. The statute does not permit the Department to obtain additional years by reason of the AO's non-action. The AO is afforded statutory opportunity to scrutinize assessments and, having elected not to do so, cannot invoke reassessment powers in the absence of new or fresh material indicating escapement of income. Resultant reassessment is invalid and relief granted to the assessee. en-us Mon, 19 Dec 2016 00:00:00 +0530 Tue, 20 Jan 2026 17:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337042 Reopening of assessment under section 147 cannot be sustained solely because the assessing officer failed to issue a notice under section 143(2); such inaction does not extend the limitation period for reassessment. The statute does not permit the Department to obtain additional years by reason of the AO's non-action. The AO is afforded statutory opportunity to scrutinize assessments and, having elected not to do so, cannot invoke reassessment powers in the absence of new or fresh material indicating escapement of income. Resultant reassessment is invalid and relief granted to the assessee. Case-Laws Income Tax Mon, 19 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337042