https://www.taxtmi.com/caselaws?id=382184 The court ruled in favor of the petitioner, quashing the reassessment notices issued under Section 148 read with Section 147 of the Income Tax Act. The court held that the reassessment proceedings lacked jurisdiction as the Assessing Officer did not have independent satisfaction and the reasons for reassessment were based on a different assessment year. Additionally, the court found the reassessment notices were time-barred as they were issued after the expiry of the extended period of six years. The court concluded that there was no failure on the part of the assessee to disclose relevant material, thus the respondent authority had no jurisdiction to invoke Sections 147 and 148 for the assessment years in question. en-us Mon, 17 Jun 2019 00:00:00 +0530 Wed, 28 Aug 2019 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=382184 The court ruled in favor of the petitioner, quashing the reassessment notices issued under Section 148 read with Section 147 of the Income Tax Act. The court held that the reassessment proceedings lacked jurisdiction as the Assessing Officer did not have independent satisfaction and the reasons for reassessment were based on a different assessment year. Additionally, the court found the reassessment notices were time-barred as they were issued after the expiry of the extended period of six years. The court concluded that there was no failure on the part of the assessee to disclose relevant material, thus the respondent authority had no jurisdiction to invoke Sections 147 and 148 for the assessment years in question. Case-Laws Income Tax Mon, 17 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=382184