Allowing the appeal of the assessee the Tribunal held that, all relevant facts were brought on record at time of assessment, in view of proviso to S.147 , reassessment is held to be not valid. (AY. 2008-09, 2012-13, 2013-14)
Pankaj Wadhwa v. ITO (2019) 174 ITD 479 (Mum.)(Trib.)
S. 147 : Reassessment-After the expiry of four years-Two house properties – Annual value -Deemed let out- All relevant facts were brought on record at time of assessment–Reassessment is bad in law. [S. 22, 23(1), 148]