Reopening U/s. 147 invalid If Reason reasons recorded have not escaped assessment

Ranbaxy Laboratories Limited Versus CIT (Delhi High Court)- The Tribunal was right in holding that the Assessing Officer had the jurisdiction to reassess issues other than the issues in respect of which proceedings are initiated but he was not so justified when the reasons for the initiation of those proceedings ceased to survive. Consequently, we answer the first part of question in affirmative in favour of Revenue and the second part of the question against the Revenue.

IN THE HIGH COURT OF DELHI AT NEW DELHI

ITA No. 148/2008

Judgment reserved on : 2^nd MAY, 2011
Judgment delivered on : 3^rd JUNE, 2011

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