https://www.taxtmi.com/caselaws?id=797399 Reassessment under Sections 147 and 148 cannot be used to revive scrutiny proceedings that lapsed because no final assessment order was completed within the period prescribed by Section 144C(4). Transfer-pricing adjustment and additional-depreciation disallowance had already been examined and included in the draft assessment order, while no fresh material indicated income escaping assessment. Reopening on identical material would improperly extend the statutory time for completing the original assessment and allow the Revenue to benefit from its failure to finalise that assessment. Reassessment in those circumstances is impermissible. en-us Tue, 24 Feb 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797399 Reassessment under Sections 147 and 148 cannot be used to revive scrutiny proceedings that lapsed because no final assessment order was completed within the period prescribed by Section 144C(4). Transfer-pricing adjustment and additional-depreciation disallowance had already been examined and included in the draft assessment order, while no fresh material indicated income escaping assessment. Reopening on identical material would improperly extend the statutory time for completing the original assessment and allow the Revenue to benefit from its failure to finalise that assessment. Reassessment in those circumstances is impermissible. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797399