https://www.taxtmi.com/caselaws?id=456481 ITAT Mumbai upheld CIT(A)'s decision quashing reassessment proceedings for AY 1999-2000 beyond six years under section 147. Following Delhi HC precedent in Brahm Datta case, tribunal held that section 149(1)(c) applies prospectively only and cannot reopen assessments beyond six-year limitation period applicable at relevant time. Revenue's reliance on SC judgment in New Delhi Television Ltd and Bombay HC decision in Soignee R. Kothari was distinguished as those cases dealt with different factual situations involving natural justice denial and non-cooperation by assessees respectively. Revenue's appeal dismissed. en-us Mon, 14 Feb 2022 00:00:00 +0530 Mon, 29 Jul 2024 20:13:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456481 ITAT Mumbai upheld CIT(A)'s decision quashing reassessment proceedings for AY 1999-2000 beyond six years under section 147. Following Delhi HC precedent in Brahm Datta case, tribunal held that section 149(1)(c) applies prospectively only and cannot reopen assessments beyond six-year limitation period applicable at relevant time. Revenue's reliance on SC judgment in New Delhi Television Ltd and Bombay HC decision in Soignee R. Kothari was distinguished as those cases dealt with different factual situations involving natural justice denial and non-cooperation by assessees respectively. Revenue's appeal dismissed. Case-Laws Income Tax Mon, 14 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456481