Morgan Ventures v. Dy. CIT (2022) 94 ITR 15 (Delhi)(Trib.)

S. 147 : Reassessment-Rectification proceedings initiated but not rectified-Reassessment proceedings initiated for same reasons-Held to be not valid. [S. 148, 154]

Held that once rectification proceedings had been initiated, then for identical reasons reassessment proceedings could not be initiated unless the rectification proceedings culminated into an order, duly framed according to the provisions of law. There was no evidence brought on record by the Revenue that the proceedings initiated under section 154 of the Act had concluded or communication to that effect had been sent to the assessee. Since the proceedings had not been completed on record, it could not be said that income had escaped assessment. Reassessment notice was quashed. (AY. 2014-15)