https://www.taxtmi.com/caselaws?id=792059 A return filed in response to a notice under section 148 cannot be used to originate a fresh claim for exemption under sections 11 and 12 where no return under section 139 was filed within time. Reassessment proceedings under section 147 are directed to bringing escaped income to tax and cannot be converted into a forum for entirely new substantive claims. Applying Sun Engineering Works and a later Special Bench view, the text explains that the deeming effect of a reassessment return does not create a new right to claim relief that was never raised in the original proceedings. en-us Thu, 14 May 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792059 A return filed in response to a notice under section 148 cannot be used to originate a fresh claim for exemption under sections 11 and 12 where no return under section 139 was filed within time. Reassessment proceedings under section 147 are directed to bringing escaped income to tax and cannot be converted into a forum for entirely new substantive claims. Applying Sun Engineering Works and a later Special Bench view, the text explains that the deeming effect of a reassessment return does not create a new right to claim relief that was never raised in the original proceedings. Case-Laws Income Tax Thu, 14 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792059