9911796707
TMI Blog2023 (5) TMI 587X X X X Extracts X X X X X X X X Extracts X X X X ..... the date of issue of notice for reassessment under section 148 (i.e.) if as on the date the assessment under section 153A or section 153C was passed, a notice under section 148 could have been issued as per the law then in force, then fresh proceedings for reassessment of such income not arising from the incriminating material found in search can now be initiated pursuant to the findings of this H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... venue to file an appropriate review application seeking the reliefs which are sought in the present application and as and when such review application is filed the same be heard and decided and disposed of in the open court. We relegate the Revenue to file an appropriate review application. - MISCELLANEOUS APPLICATION NO. 680 OF 2023 IN CIVIL APPEAL NO. 6580 OF 2021 - - - Dated:- 12-5-2023 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he findings of this Hon ble Court in the present appeals/application and may further clarify as follows: (i) That the findings in para 11 and 14 would apply to all the proceedings pending in all the forums including before this Hon ble Court. (ii) That even though the appeals of the Revenue are dismissed in respect of assessments passed under 153A and 153C, in the absence of incriminat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orm of clarification is not entertained and we relegate the Revenue to file an appropriate review application for the relief sought in the present application and as and when such review application is filed the same can be heard in the open court. 3. In view of the above and without further entering into the merits of the application and/or expressing anything on merits on the prayers sought i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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