https://www.taxtmi.com/caselaws?id=463114 The ITAT Amritsar held the reassessment notice under section 148 invalid as it was served beyond the prescribed time limit under the proviso to section 143(2)(ii). The AO's satisfaction to initiate reassessment was found to be borrowed from the Assistant Director of Investigation without independent application of mind, rendering the reassessment proceedings under section 147 void. Consequently, the reassessment order was quashed. Due to the invalidity of the reassessment, the tribunal did not adjudicate the substantive additions or procedural issues raised, including the confirmation of additions without confronting the assessee or allowing cross-examination, and the non-simultaneous disposal of protective and substantive appeals. The decision reaffirmed the necessity of strict compliance with statutory time limits and independent satisfaction by the AO for valid reassessment proceedings. en-us Wed, 05 Sep 2012 00:00:00 +0530 Thu, 07 Aug 2025 11:34:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463114 The ITAT Amritsar held the reassessment notice under section 148 invalid as it was served beyond the prescribed time limit under the proviso to section 143(2)(ii). The AO's satisfaction to initiate reassessment was found to be borrowed from the Assistant Director of Investigation without independent application of mind, rendering the reassessment proceedings under section 147 void. Consequently, the reassessment order was quashed. Due to the invalidity of the reassessment, the tribunal did not adjudicate the substantive additions or procedural issues raised, including the confirmation of additions without confronting the assessee or allowing cross-examination, and the non-simultaneous disposal of protective and substantive appeals. The decision reaffirmed the necessity of strict compliance with statutory time limits and independent satisfaction by the AO for valid reassessment proceedings. Case-Laws Income Tax Wed, 05 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463114