Fresh Reassessment Pending conclusion of first reassessment proceedings is invalid

Shri Jaideep Singh Vs ITO (ITAT Jaipur)

A question that arises for con sideration is whether the AO can issue second notice u/s 148 and initiate fresh reassessment proceedings before completion/conclusion of proceedings initiated by way of first notice u/s 148 either by way of dropping the first reassessment proceedings or completing the proceedings by passing the reassessment order u/s 147 of the Act. As we have noted above, the assessee has raised a specific objection against initiation of the first reassessment proceedings vide its letter dated 21.01

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