https://www.taxtmi.com/caselaws?id=762423 In a challenge to reassessment under s.147, the dominant issue before the SC was whether the petitioner could press a factual contention regarding absence of valid sanction when such contention was allegedly raised only in rejoinder and was not recorded or considered in the impugned HC judgment. The SC held that, since the impugned judgment did not reflect that the contention was agitated, any grievance that it was argued but not noted lay by way of an appropriate application before the HC. Consequently, the SLP was disposed of as withdrawn, leaving the petitioner to pursue relief before the HC. en-us Tue, 26 Nov 2024 00:00:00 +0530 Fri, 26 Dec 2025 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762423 In a challenge to reassessment under s.147, the dominant issue before the SC was whether the petitioner could press a factual contention regarding absence of valid sanction when such contention was allegedly raised only in rejoinder and was not recorded or considered in the impugned HC judgment. The SC held that, since the impugned judgment did not reflect that the contention was agitated, any grievance that it was argued but not noted lay by way of an appropriate application before the HC. Consequently, the SLP was disposed of as withdrawn, leaving the petitioner to pursue relief before the HC. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762423