https://www.taxtmi.com/caselaws?id=785162 Whether the reopening under section 147 was valid: Tribunal finds the assessing officer's assumption of jurisdiction flawed because the appellate authority accepted that accumulated funds were not utilisable due to a court injunction and that prior years' excess expenditure could be set off against the unutilized fund per binding higher-court precedent upheld by the SC; legally, no income had escaped assessment for the year in question. Outcome: reopening under s.147 invalidated and the assessment relief upheld. Whether merits of allowance of relief were correct: CIT(A) properly applied statutory provisions and the injunction context; outcome: order affirmed and revenue's grounds dismissed. en-us Fri, 09 Jan 2026 00:00:00 +0530 Mon, 19 Jan 2026 07:36:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785162 Whether the reopening under section 147 was valid: Tribunal finds the assessing officer's assumption of jurisdiction flawed because the appellate authority accepted that accumulated funds were not utilisable due to a court injunction and that prior years' excess expenditure could be set off against the unutilized fund per binding higher-court precedent upheld by the SC; legally, no income had escaped assessment for the year in question. Outcome: reopening under s.147 invalidated and the assessment relief upheld. Whether merits of allowance of relief were correct: CIT(A) properly applied statutory provisions and the injunction context; outcome: order affirmed and revenue's grounds dismissed. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785162