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    <title>1967 (7) TMI 30 - KERALA High Court</title>
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    <description>Reassessment under the Income-tax Act could not be sustained where the alleged escapement was tied to a different assessment year and there was no omission to disclose material facts for the year sought to be reopened. The amount had already been examined in later proceedings, and it could not be recast as escaped income of the earlier year to invoke reassessment powers. On these undisputed facts, section 147(a) was held inapplicable, the notice under section 148 was without jurisdiction and time-barred, and the impugned reassessment proceedings were set aside.</description>
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      <title>1967 (7) TMI 30 - KERALA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=7098</link>
      <description>Reassessment under the Income-tax Act could not be sustained where the alleged escapement was tied to a different assessment year and there was no omission to disclose material facts for the year sought to be reopened. The amount had already been examined in later proceedings, and it could not be recast as escaped income of the earlier year to invoke reassessment powers. On these undisputed facts, section 147(a) was held inapplicable, the notice under section 148 was without jurisdiction and time-barred, and the impugned reassessment proceedings were set aside.</description>
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      <pubDate>Tue, 11 Jul 1967 00:00:00 +0530</pubDate>
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