Adonis Marketing (P) Ltd.,Kolkata vs I.T.O., Ward - 9(1), , Kolkata on 6 February, 2025
has categorically held that the recourse can be taken to section 147 after the
expiry of the limitation fixed for framing the original assessment. The said
decision has been further followed by the Hon'ble Madras High court in the
case of CIT Vs. KLM Royal Dutch Airlines (supra) relevant part of the order of
the Hon'ble Madras High court has reproduced as under: