Section 147/148 Proceedings Not Permissible During Pendency of Section 154 Proceedings: SC

S.M. Overseas Pvt. Ltd. Vs CIT (Supreme Court of India) In the case S.M. Overseas Pvt. Ltd. vs. CIT, the Supreme Court of India overturned a Punjab and Haryana High Court decision concerning the reopening of income tax assessment for the assessment year 1995–96. The dispute centered around the Income Tax Department’s attempt to reassess the company under Sections 147 and 148 of the Income Tax Act, despite ongoing rectification proceedings under Section 154. Initially, the Income Tax Appellate Tribunal (ITAT) had ruled in favor of the assessee, quashing the reassessment on grounds that ...