https://www.taxtmi.com/caselaws?id=421141 The Gujarat High Court examined the issue of reopening assessments under Section 153A of the Income Tax Act by issuing notices under Section 148. The court clarified that while Section 153A assessments are comprehensive, they are not infallible and can be reopened under Section 147 if new material is discovered. The court emphasized the legislative intent and procedural aspects, ultimately deciding that reopening under Section 147 is permissible in specific circumstances. The matters were scheduled for further hearing to determine if the Revenue established a case for reopening assessments under Section 153A. en-us Mon, 31 Jan 2022 00:00:00 +0530 Mon, 27 Apr 2026 17:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421141 The Gujarat High Court examined the issue of reopening assessments under Section 153A of the Income Tax Act by issuing notices under Section 148. The court clarified that while Section 153A assessments are comprehensive, they are not infallible and can be reopened under Section 147 if new material is discovered. The court emphasized the legislative intent and procedural aspects, ultimately deciding that reopening under Section 147 is permissible in specific circumstances. The matters were scheduled for further hearing to determine if the Revenue established a case for reopening assessments under Section 153A. Case-Laws Income Tax Mon, 31 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421141