https://www.taxtmi.com/caselaws?id=15390 For limitation under section 153, the period during which reassessment proceedings remained stayed by court order was excluded, and the Explanation was treated as applicable to reassessment as part of the assessment proceeding. The assessee could not rely on its own stay order to exhaust limitation, so the limitation objection failed. On opportunity and disclosure, the reassessment was upheld because notice under section 148 had been served, no return was filed, and the assessee did not rebut the material relied on; no prejudice from nondisclosure was shown. However, inclusion of Rs. 2,25,200 was not sustained because it had already been accepted in the original assessment and no fresh material justified its addition in reassessment. en-us Wed, 28 Oct 1998 00:00:00 +0530 Thu, 06 Aug 2009 12:34:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15390 For limitation under section 153, the period during which reassessment proceedings remained stayed by court order was excluded, and the Explanation was treated as applicable to reassessment as part of the assessment proceeding. The assessee could not rely on its own stay order to exhaust limitation, so the limitation objection failed. On opportunity and disclosure, the reassessment was upheld because notice under section 148 had been served, no return was filed, and the assessee did not rebut the material relied on; no prejudice from nondisclosure was shown. However, inclusion of Rs. 2,25,200 was not sustained because it had already been accepted in the original assessment and no fresh material justified its addition in reassessment. Case-Laws Income Tax Wed, 28 Oct 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15390