https://www.taxtmi.com/caselaws?id=446660 The tribunal reasoned that the assessing officer may reassess only income not already made the subject of an existing appeal; income under challenge in a pending appeal is excluded by the third proviso to Section 147. The court examined the grounds of appeal for the relevant years and found the revenue's appeals specifically targeted additions treated as unexplained credits; reassessment proceedings also attacked those same additions. Because the identical additions were the subject matter of pending appeals, the reassessment was impermissible and was quashed. The judgment applies precedents endorsing examination of appeal grounds to identify excluded issues. en-us Tue, 07 Nov 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446660 The tribunal reasoned that the assessing officer may reassess only income not already made the subject of an existing appeal; income under challenge in a pending appeal is excluded by the third proviso to Section 147. The court examined the grounds of appeal for the relevant years and found the revenue's appeals specifically targeted additions treated as unexplained credits; reassessment proceedings also attacked those same additions. Because the identical additions were the subject matter of pending appeals, the reassessment was impermissible and was quashed. The judgment applies precedents endorsing examination of appeal grounds to identify excluded issues. Case-Laws Income Tax Tue, 07 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446660