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Reassessment u/s 147 invalid if original tax assessment is pending; Section 148 notice requires concluded proceedings.
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....Reopening of assessment u/s 147 where assessment proceedings already pending - Unless the return of income already filed is disposed of, the notice for reassessment u/s 148 cannot be issued, i.e. no reassessment proceedings can be initiated so long as the assessment proceedings pending on the basis of the return already filed are not terminated - it looks absurd to call for a return u/s 148....
TaxTMI
TaxTMI