https://www.taxtmi.com/caselaws?id=309026 Reassessment under Sections 147 and 148 may proceed during a pending appeal before the CIT(A) where it concerns transactions distinct from those examined in the original assessment or appellate proceedings. A reassessment notice concerning previously unexamined cash deposits was treated as based on an independent issue rather than a change of opinion, with the required reason to believe considered satisfied. The Assessing Officer's reassessment jurisdiction is not displaced by the CIT(A)'s appellate powers under Section 251. Objections that replies were not adequately considered should be pursued through the statutory appellate mechanism, rather than writ jurisdiction, where the tax statute provides a complete assessment and reassessment framework. en-us Fri, 22 Jul 2022 00:00:00 +0530 Tue, 03 Feb 2026 13:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309026 Reassessment under Sections 147 and 148 may proceed during a pending appeal before the CIT(A) where it concerns transactions distinct from those examined in the original assessment or appellate proceedings. A reassessment notice concerning previously unexamined cash deposits was treated as based on an independent issue rather than a change of opinion, with the required reason to believe considered satisfied. The Assessing Officer's reassessment jurisdiction is not displaced by the CIT(A)'s appellate powers under Section 251. Objections that replies were not adequately considered should be pursued through the statutory appellate mechanism, rather than writ jurisdiction, where the tax statute provides a complete assessment and reassessment framework. Case-Laws Income Tax Fri, 22 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309026