On writ the Court held that the petitioner shall pursue the proceedings before the Commissioner (Appeals) against the impugned assessment order as also the proceedings before the Revisionary Authority. It is open to the petitioner to raise contentions in regard to the illegality of the notice issued to the petitioner under section 148.. Till the proceedings before the Appellate Authority or Revisionary Authority are decided, the assessment order shall remain stayed. All contentions of the petitioner on the pending proceedings are expressly kept open. (AY. 2018-19)
Real Infrastructure Co. v. ITO (2025) 302 Taxman 116 (Bom.)(HC)
S. 144 : Best judgment assessment-Pendency of appeal and revision-Assessment order is stayed till proceedings before Appellate Authority or Revisional Authority were decided. [S. 144B, 148, 246A, 264, Art. 226]
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