Reassessment Proceedings u/s 147 Dismissed for Being Time-Barred; Department Fails to Prove Compliance with Proviso Conditions. https://www.taxtmi.com/highlights?id=65348 Reopening of assessment u/s 147 - whether Assessment barred by limitation? - Since the burden of establishing the satisfaction of the statutory condition set out in the proviso rests fully upon the Department, and such burden has not been discharged in the present case, the impugned proceedings for reassessment fail. - HC en-us Tue, 30 Aug 2022 12:44:50 +0530 Tue, 30 Aug 2022 12:44:50 +0530 TaxTMI RSS Generator Reassessment Proceedings u/s 147 Dismissed for Being Time-Barred; Department Fails to Prove Compliance with Proviso Conditions. https://www.taxtmi.com/highlights?id=65348 Reopening of assessment u/s 147 - whether Assessment barred by limitation? - Since the burden of establishing the satisfaction of the statutory condition set out in the proviso rests fully upon the Department, and such burden has not been discharged in the present case, the impugned proceedings for reassessment fail. - HC Highlights Income Tax Tue, 30 Aug 2022 12:44:50 +0530 https://www.taxtmi.com/highlights?id=65348