Income-Tax Officer Can Initiate Section 147 Proceedings if Higher Forum Reassigns Income to Different Year.

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....If any income from an assessment by a higher forum on the ground that it is not the income of that year, the Income-tax Officer has jurisdiction to initiate proceedings u/s 147 to assess it as the income of another year without any limitation applying to the issue of the notice u/s 148 or to the completion of the assessment or reassessment - HC....