https://www.taxtmi.com/caselaws?id=24730 Whether section 153(2A) applies where Explanation 2 to section 153 creates a legal fiction for reassessment: HC held that, construing the fiction purposively, fresh assessments made pursuant to findings/directions in appellate or revisional orders (s.250, s.254, s.263, s.264) must be deemed to have been made "in consequence of" those orders so as to fall within s.153(2A); excluding s.153(2A) would defeat the statutory purpose and nullify the fiction. Outcome: s.153(2A) is applicable to such reassessments, and the reference was decided in favour of the assessee; parties to bear their own costs. en-us Thu, 27 Aug 1987 00:00:00 +0530 Wed, 14 Jan 2026 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24730 Whether section 153(2A) applies where Explanation 2 to section 153 creates a legal fiction for reassessment: HC held that, construing the fiction purposively, fresh assessments made pursuant to findings/directions in appellate or revisional orders (s.250, s.254, s.263, s.264) must be deemed to have been made "in consequence of" those orders so as to fall within s.153(2A); excluding s.153(2A) would defeat the statutory purpose and nullify the fiction. Outcome: s.153(2A) is applicable to such reassessments, and the reference was decided in favour of the assessee; parties to bear their own costs. Case-Laws Income Tax Thu, 27 Aug 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24730