Held that the initiation of reassessment proceedings under section 147 for the assessment year 2011-12 was in excess of jurisdiction and barred by limitation. For the assessment year 2013-14, the order in the writ petition relegating the matter to the assessing authority was not interfered with.(AY.2011-12, 2013-14)
Durr India Pvt. Ltd. v. ACIT (2023)455 ITR 460 /335 CTR 444/152 taxmann.com 303 (Mad)(HC) Editorial: Decision of the single judge Durr India Pvt. Ltd. v. ACIT (2021) 433 ITR 48 (Mad)(HC),/./ SLP of Revenue is dismissed , ACIT (OSD) v. Durr India (P.) Ltd. (2024) 297 Taxman 58 (SC) affirmed
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is barred by limitation- -Issue not discussed in original assessment-No opinion formed-Matter relegated to Assessing Officer. [S. 148, Art. 226]