https://www.taxtmi.com/caselaws?id=12153 The court ruled in favor of the petitioner, a limited foreign company, in a case challenging notices issued for reassessment beyond the prescribed four-year period under the Income-tax Act. The court found that the notices were issued without any failure on the part of the assessee as required by the proviso to section 147. The court emphasized that the reasons provided for reassessment did not establish any failure or omission by the assessee, and reliance on certain sections was deemed insufficient to override the conditions of the proviso. Consequently, the court allowed the petition, quashing the impugned notices. en-us Fri, 25 Oct 2002 00:00:00 +0530 Wed, 17 Feb 2010 19:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12153 The court ruled in favor of the petitioner, a limited foreign company, in a case challenging notices issued for reassessment beyond the prescribed four-year period under the Income-tax Act. The court found that the notices were issued without any failure on the part of the assessee as required by the proviso to section 147. The court emphasized that the reasons provided for reassessment did not establish any failure or omission by the assessee, and reliance on certain sections was deemed insufficient to override the conditions of the proviso. Consequently, the court allowed the petition, quashing the impugned notices. Case-Laws Income Tax Fri, 25 Oct 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12153