PCIT v. Sanjay Mehta (2024) 298 Taxman 673 (Cal.)(HC)

S. 147 : Reassessment-After the expiry of four years-Order passed without disposing the objection-Order of Tribunal quashing the assessment order is held be justified. [S. 148, 260A]

The Assessing Officer issued on the assessee a notice under section 148 seeking to reopen his assessment.The Assessing Officer thereafter passed assessment order without disposing of the objections given by the assessee for initiation of reassessment and made addition in his income.

The Tribunal quashed the reopening of the assessment and deleted the addition made by the Assessing Officer. On appeal the Court held that on considering the factual position rightly noted that the objections given by the assessee for initiation of reassessment were not disposed of by the Assessing Officer.The law on the subject has been rightly taken note by the Tribunal.The matter being entirely factual, no question of law much less substantial question of law arises for consideration.  (AY. 2013-14)