High Court held that since petition was filed after a delay of almost one year and that too just few days before final assessment order came to be passed and there was no explanation as to why petition was filed after such delay, assessee should exhaust its alternative remedies under provisions of Income-tax Act before approaching High Court -SLP the Court held that in view of decision of Supreme Court in UOI v. Rajeev Bansal [2024]301 Taxman 238/469 ITR 46(SC) final assessment order was quashed only for purpose of enabling assessee to raise all objections and contentions vis-a-vis impugned notices. Order of High Court set aside.
Seahorse Mercantile Company (P.) Ltd. v. ITO (2025) 304 Taxman 277 (SC) Editorial : Seahorse Mercantile Company (P.) Ltd. v. ITO (2025)172 ITR 162 (Bom)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Order of High Court set aside in view of UOI v. Rajeev Bansal [2024]301 Taxman 238/469 ITR 46(SC) final assessment order was quashed only for purpose of enabling assessee to raise all objections and contentions vis-a-vis impugned notices.[S. 148, 148A(b), 148A(d), Art. 136]
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