C. L. Chandradhara. v. CIT (2019) 55 CCH 0468/ 71 ITR 246 (Bang.)(Trib.)

S. 147 : Reassessment-Reasons for reopening was communicated to assessee –No objections made by assessee-AO assumed valid jurisdiction-Reassessment is held to be valid. [S. 148, 151]

Assessee had requested for reasons for reopening on 05. 11. 2007.  However, the same was served to the assessee on 12. 02. 2008.  However, assessee did not raise any objections in this regard and subsequently challenged the validity of assumption of jurisdiction by AO under section.  147/148 for commencing reassessment proceedings. The Tribunal held that the assessee has asked for reasons for reopening which were validly served to the assessee and that the AO has validly and correctly assumed jurisdiction under S.  147 of the Act for commencing reassessment proceedings. Thus, there is no violation of provisions contained in S. 151 of the Act.  Thus, the appeal of the assessee is dismissed. (AY.  1995-96 to 1998-99)