https://www.taxtmi.com/caselaws?id=786729 The amended proviso to Section 251(1)(a) confines the power to set aside and remit an assessment to best-judgment assessments made under Section 144, excluding assessments completed under Section 143(3). Reassessment under Sections 147 and 148 requires recorded reasons showing income chargeable to tax escaped assessment for the relevant year; reopening is unsustainable where it duplicates identical share capital or share premium receipts already assessed in another year. Approval under Section 151(2) requires the sanctioning authority's independent application of mind and is invalid when granted mechanically on repeated reasons or transactions. 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 amended proviso to Section 251(1)(a) confines the power to set aside and remit an assessment to best-judgment assessments made under Section 144, excluding assessments completed under Section 143(3). Reassessment under Sections 147 and 148 requires recorded reasons showing income chargeable to tax escaped assessment for the relevant year; reopening is unsustainable where it duplicates identical share capital or share premium receipts already assessed in another year. Approval under Section 151(2) requires the sanctioning authority's independent application of mind and is invalid when granted mechanically on repeated reasons or transactions. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786729