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Rakesh Kumar Agarwal, Kanpur vs Astt. Commissioner Of Income Tax-3, ... on 22 February, 2018

In Rakesh Aggarwal v. Asstt. CIT[1997] 225 ITR 4961, the Delhi High Court held that in view of the proviso to section 147 notice for reassessment under section 147/148 should only be issued in accordance with the new section 147, and where the original assessment had been made under section 143(3), then in view of the proviso to section 147 the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year.
Income Tax Appellate Tribunal - Lucknow Cites 5 - Cited by 7 - Full Document

Rajinder Nath Etc vs Commissioner Of Income Tax, Delhi on 13 August, 1979

A direction or finding as contemplated by section 153(3)(ii ) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee and in relevance to a particular assessment year. To be a necessary finding it must be directly involved in the disposal of the case. To be a direction as contemplated by section 153(3)(ii) it must be an express direction necessary for the disposal of the case before the authority or court vide Rajinder Nath v. CIT[1979]120 ITR 141 (SC); Gupta 14 ITA No s .
Supreme Court of India Cites 7 - Cited by 139 - R S Pathak - Full Document
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