Tribunal Upholds Appeal: Reopening of Tax Assessment u/s 147 Invalid Due to Expired Statutory Period.

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....Reopening of assessment u/s 147 - Period of limitation - The audit party is entitled to point out a factual error or omission in the assessment. reopening of the assessment in the light of factual errors pointed out by the audit party is permissible under law. In the present case, even though the assessment was reopened on the basis of the error pointed out by the revenue audit, the same was done after the period prescribed u/s 147. Tribunal is right in allowing the appeal filed by the assessee. - HC....