https://www.taxtmi.com/caselaws?id=311059 ITAT Raipur quashed the Pr. CIT's order under Section 263 after finding that the underlying reassessment order under Section 143(3) read with Section 147 was invalid. The AO had issued notice under Section 148 beyond the four-year limitation period without valid reasons as required under the first proviso to Section 147. Since the original reassessment was based on invalid assumption of jurisdiction and was non-est, the Pr. CIT could not revise it under Section 263. The tribunal held that validity of primary proceedings can be challenged in collateral proceedings and decided in favor of the assessee. en-us Mon, 31 Oct 2022 00:00:00 +0530 Tue, 05 Dec 2023 21:03:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311059 ITAT Raipur quashed the Pr. CIT's order under Section 263 after finding that the underlying reassessment order under Section 143(3) read with Section 147 was invalid. The AO had issued notice under Section 148 beyond the four-year limitation period without valid reasons as required under the first proviso to Section 147. Since the original reassessment was based on invalid assumption of jurisdiction and was non-est, the Pr. CIT could not revise it under Section 263. The tribunal held that validity of primary proceedings can be challenged in collateral proceedings and decided in favor of the assessee. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311059