No Section 147 Assessment in absence of reasons for escapement of income

Kailash Kanhaiyalal Gidwani Vs ACIT (ITAT Pune)

The issue under consideration is that whether the initiation of assessment proceedings and the consequential assessment order passed u/s 147 of the Act is valid or not?

In the present case, even though the original summary assessment was made u/s 143(1) of the Act and the period of four years from the end of the assessment year had not expired before issuing notice u/s 148 of the Act, still, the AO, having missed the opportunity of making assessment u/s

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