https://www.taxtmi.com/caselaws?id=786729 The article addresses three tax-procedure points: the amended proviso to Section 251(1)(a) limits the power to set aside and remit only to best judgment assessments made under Section 144, so such power does not extend to assessments framed under Section 143(3), and any remand on that basis is void; reopening under Section 147/148 is unsustainable where reasons do not show income chargeable escaped assessment and identical receipts were already assessed in another year; and sanction under Section 151(2) is vitiated if granted mechanically without independent application of mind, invalidating the notice issuance. en-us Mon, 16 Feb 2026 00:00:00 +0530 Wed, 18 Feb 2026 08:12:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786729 The article addresses three tax-procedure points: the amended proviso to Section 251(1)(a) limits the power to set aside and remit only to best judgment assessments made under Section 144, so such power does not extend to assessments framed under Section 143(3), and any remand on that basis is void; reopening under Section 147/148 is unsustainable where reasons do not show income chargeable escaped assessment and identical receipts were already assessed in another year; and sanction under Section 151(2) is vitiated if granted mechanically without independent application of mind, invalidating the notice issuance. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786729