Reassessment u/s. 148 on same ground already considered by AO cannot be sustained

Urvashi Kanubhai Desai Vs ITO (Gujarat High Court) Gujarat High Court held that the proceedings under Section 148 of the Income Tax Act cannot be initiated to review the earlier stand adopted by the Assessing Officer. Accordingly, initiation of reassessment proceedings u/s. 148A(d) on the same ground which is already considered by AO cannot be sustained. Facts- The petitioner is an individual and engaged in the business of data, data selling and purchasing under the trade name “Excellere Outsourcing Services.” It is the case of the petitioner that subsequent to filing of the return of inco...