https://www.taxtmi.com/caselaws?id=344607 The court invalidated the reopening of assessment under Section 147, emphasizing that the issue of the receipt's taxability was already under appeal, applying the principle of merger. The court set aside the notice for reopening the assessment, highlighting that reassessing income already subject to appellate consideration would result in impermissible dual adjudication. The court refrained from expressing an opinion on the receipt's nature or tax treatment, deferring this determination to the pending appellate proceedings. en-us Wed, 14 Jun 2017 00:00:00 +0530 Wed, 17 Jan 2018 10:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344607 The court invalidated the reopening of assessment under Section 147, emphasizing that the issue of the receipt's taxability was already under appeal, applying the principle of merger. The court set aside the notice for reopening the assessment, highlighting that reassessing income already subject to appellate consideration would result in impermissible dual adjudication. The court refrained from expressing an opinion on the receipt's nature or tax treatment, deferring this determination to the pending appellate proceedings. Case-Laws Income Tax Wed, 14 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344607