https://www.taxtmi.com/caselaws?id=384538 Reassessment under section 147 could not be sustained where the recorded reasons related to matters already pending in appeal, because the proviso excludes income forming the subject matter of appellate, revisional, or reference proceedings. The tribunal also applied binding High Court rulings that electricity duty and allied statutory amounts held by the assessee were not disallowable under section 43B as a liability payable to the sovereign in a fiduciary capacity, and that section 115JB did not apply to a statutory corporation not treated as a company under the Companies Act. The reopening and the additions were therefore unsustainable. en-us Thu, 08 Aug 2019 00:00:00 +0530 Wed, 14 Aug 2019 12:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384538 Reassessment under section 147 could not be sustained where the recorded reasons related to matters already pending in appeal, because the proviso excludes income forming the subject matter of appellate, revisional, or reference proceedings. The tribunal also applied binding High Court rulings that electricity duty and allied statutory amounts held by the assessee were not disallowable under section 43B as a liability payable to the sovereign in a fiduciary capacity, and that section 115JB did not apply to a statutory corporation not treated as a company under the Companies Act. The reopening and the additions were therefore unsustainable. Case-Laws Income Tax Thu, 08 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384538