Revenue’s Right to Reassess Doesn’t Override Sec 149 Limitation: Delhi HC

ARN Infrastructures India Limited Vs ACIT (Delhi High Court)

Liberty to Revenue to initiate reassessment proceedings in Abhisar Buildwell didn’t construe to overcome Limitation u/s 149

Conclusion: Power of Revenue to initiate reassessment proceedings under Sections 147/148 in case of completed/ unabated assessment, if no incriminating material was found during the search- could not be construed to be an authority to override the limitation prescribed under Section 149.

Held: In the instant case, proceedings for reassessment init

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