2023 (5) TMI 587

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....For the Respondent : Ambhoj Kumar Sinha [ R - 1 ] JUDGMENT M. R. Shah , J. 1. Present Miscellaneous Application has been preferred by the Revenue seeking following prayers: "(a) This Hon'ble Court may clarify that the waiver of limitation as stipulated in section 150(2) is to be read in respect of the date of issue of notice for reassessment under section 148 (i.e.) if as on the ....

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....sessment other than through incriminating material, the assessing officers would be entitled to reassess such income in terms of Section 147/148 read with section 150. (iii) That the Assessing Officer, may if found necessary initiate fresh proceedings within 60 days from date of disposal of this application following the procedure stipulated in section 147-151 of the Act as is in force no....