Taxpayer's Challenge to Section 147 Reassessment Fails Due to Delayed TOLA Objections and Factual Examination Requirements

HC dismissed writ petition challenging reassessment proceedings under Section 147. Court declined jurisdiction noting petitioner's failure to raise TOLA provisions applicability in initial objections, making it inappropriate to address first time in writ. Questions about Section 54F deductions and rental income taxation involved factual determinations unsuitable for writ jurisdiction. While audit-based reopening was contested, Court held distinction between fact-based and law-based audit objections requires factual examination. Petitioner's participation in proceedings without timely objections weakened procedural challenges. Court granted 4-week extension of interim relief for appeal filing and stay application, directing appellate authority to consider all grounds including procedural objections. .....

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