https://www.taxtmi.com/caselaws?id=18686 The High Court dismissed reference applications concerning the reopening of assessments under section 147(a) of the Income-tax Act, 1961. The Assessing Officer's notice under section 148 was deemed invalid due to procedural errors, leading to a limitation on assessment. The Tribunal's decision, supported by legal precedents, emphasized that factual findings on limitations are conclusive and not subject to review unless proven erroneous. The High Court affirmed that such findings do not raise legal questions, highlighting the significance of factual accuracy and adherence to precedents in assessment matters. The reference applications were rejected without costs. en-us Wed, 22 Nov 1995 00:00:00 +0530 Sat, 31 Oct 2009 13:23:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18686 The High Court dismissed reference applications concerning the reopening of assessments under section 147(a) of the Income-tax Act, 1961. The Assessing Officer's notice under section 148 was deemed invalid due to procedural errors, leading to a limitation on assessment. The Tribunal's decision, supported by legal precedents, emphasized that factual findings on limitations are conclusive and not subject to review unless proven erroneous. The High Court affirmed that such findings do not raise legal questions, highlighting the significance of factual accuracy and adherence to precedents in assessment matters. The reference applications were rejected without costs. Case-Laws Income Tax Wed, 22 Nov 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18686