Commissioner of Wealth Tax (Appeals) erred in not holding that the reassessment under Section 17 of Wealth Tax Act was bad in law, beyond jurisdiction ... Appeals) erred on facts and in law in holding that the reassessment was had in law, being based on mere change of opinion.
3. That
shall proceed against each such other
person and issue notice assess or reassess the income of the
other person in accordance with the provisions ... other person can issue a notice to that person and assess or
reassess his income in accordance with the provisions of
Section 153A . Therefore, before
doubt that assessment under Section 143 and assessments and reassessments under Section 147 are different, but in making assessments and reassessments under Section ... that Section 148 of the Act applies to assessment as well as reassessment cases and no different treatment is prescribed for either of the cases
suspect". In this view of the matter he annulled the reassessment holding it to be null and void. He did not decide the merits ... appellant on this point is misconceived. The proceedings for assessment or reassessment under Section 34(1)(a) of the Income-tax Act start with
assessee filed return for both the years on 23rd May, 1990. Reassessment was completed by the AO on 31st Oct., 1990. Against this reassessment order ... issued on 20th April, 1990. The AO during the course of the reassessment proceedings pointed out that assessment was reopened to vaery the deduction under
which were duly complied. The assessee objected initiation of
reassessment proceedings after the expiry of four years from ... Government
Approvals" amounting to Rs. 56, 54, 840/- in the reassessment
completed. Regarding the direction of the Tribunal for examining
the depreciation
31st October 2007, the reassessment notice was issued on 30th March
2012, on recording, inter alia, the following reasons of reopening the assessment:
Subsequently, information ... discussions about the stand of the assessee against the
initiation of these reassessment proceedings, the ground of appeal take before the CIT(A)
show
assessment year 1999-2000 originally no such addition was made. However,
reassessment proceedings were started by issuance of notice under section 143(2)
read with ... section 147 of the Act and the Tribunal quashed those reassessment
proceedings. It is not necessary to go into the question as to whether reassessment
August 28, 2003,
under section 148 of the Income-tax Act for reassessment of income for the year in
question under section ... Assessing Officer to
furnish reasons to the petitioner for the decision to reassess income under section 147
of the Income-tax Act.
14. On September
provisions of Section 153 A does not provide and contemplate assessment or reassessment in respect of any income which has already been considered ... could not be invoked to make an assessment or reassessment of income just because a search had taken place in the case of an assessee
