https://www.taxtmi.com/caselaws?id=754051 The Jharkhand HC dismissed writ petitions challenging reassessment proceedings under section 147. The petitioner argued reassessment was time-barred under the first proviso to unamended section 147, claiming no reassessment could be initiated after four years without assessee's omission or failure to disclose. The HC held that the petitioner's conduct disentitled him from invoking extraordinary writ jurisdiction due to delayed filing of return in response to section 148 notice and non-compliance with section 142(1) notice and show-cause notice. The court noted the petitioner never challenged the reassessment notice, reasons to believe, or section 151 sanction, and only approached the court after reassessment concluded without preferring statutory appeal. The HC found the matter required factual adjudication beyond Article 226 scope and dismissed all writ applications, directing the petitioner to pursue statutory appellate remedy. en-us Tue, 11 Jun 2024 00:00:00 +0530 Sat, 15 Jun 2024 08:22:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754051 The Jharkhand HC dismissed writ petitions challenging reassessment proceedings under section 147. The petitioner argued reassessment was time-barred under the first proviso to unamended section 147, claiming no reassessment could be initiated after four years without assessee's omission or failure to disclose. The HC held that the petitioner's conduct disentitled him from invoking extraordinary writ jurisdiction due to delayed filing of return in response to section 148 notice and non-compliance with section 142(1) notice and show-cause notice. The court noted the petitioner never challenged the reassessment notice, reasons to believe, or section 151 sanction, and only approached the court after reassessment concluded without preferring statutory appeal. The HC found the matter required factual adjudication beyond Article 226 scope and dismissed all writ applications, directing the petitioner to pursue statutory appellate remedy. Case-Laws Income Tax Tue, 11 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754051