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The High Court of Calcutta ruled that the reassessment proceedings under section 147 of the Income-tax Act were not validly initiated as the assessee had already been assessed in a regular manner and the new findings were not in existence at the time of the original assessment. The Tribunal's decision to quash the reassessment proceedings was upheld. The judgment was agreed upon by Judges K. M. Yusuf and Ajit Kumar Sengupta.
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