2004 (9) TMI 18

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....t P6 revisional order of the Commissioner of Income-tax issued under section 264 of the Income-tax Act, 1961, refusing to interfere with exhibit P3 issued by the Assessing Officer overruling the petitioner's objections against reopening of assessments under section 147 of the Act. The income-tax assessments of the petitioner for the assessment years 1996-97 to 2001-02 completed under section 143(....

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....s. Pursuant to exhibit P5 judgment, the Assessing Officer issued exhibit P3 order wherein he overruled the petitioner's objections filed against reopening of assessments and proceeded to complete the assessments under section 147 read with section 143(3) of the Act. The petitioner challenged exhibit P3 in a revision before the Commissioner of Income-tax who rejected it vide exhibit P6 order, which....

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.... the appeals filed before the Commissioner of Income-tax (Appeals) against the revised assessments. The petitioner, probably, filed this writ petition on the apprehension that in view of exhibit P6 order of the Commissioner of Income-tax upholding the reopening of assessments, that issue may not be open for decision by the Commissioner of Income-tax (Appeals), in the course of disposal of appeals ....

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....suant to a notice under section 148 and along with it raises objections against reopening of assessments, such objections can be adjudicated in the revised assessment order itself. The remedy against reassessment so completed is to file a statutory appeal covering all aspects against assessment including the reopening. However, if the assessee does not choose to file a return under section 148 of ....