https://www.taxtmi.com/caselaws?id=17860 A reassessment under section 147 is legally distinct from an assessment under section 143(3), so a procedural provision confined by its text to assessments under section 143(3) cannot be extended to reassessment proceedings. On that reasoning, section 144B did not apply to reassessment under section 147, and the extended time-limit in the Explanation to section 153 was likewise unavailable for such proceedings. The Court therefore answered the reference in favour of the assessee and against the Department. en-us Thu, 25 Apr 1996 00:00:00 +0530 Fri, 25 Sep 2009 12:46:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17860 A reassessment under section 147 is legally distinct from an assessment under section 143(3), so a procedural provision confined by its text to assessments under section 143(3) cannot be extended to reassessment proceedings. On that reasoning, section 144B did not apply to reassessment under section 147, and the extended time-limit in the Explanation to section 153 was likewise unavailable for such proceedings. The Court therefore answered the reference in favour of the assessee and against the Department. Case-Laws Income Tax Thu, 25 Apr 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17860