Case Law Analysis
|Income Tax Appellate Tribunal
Section 147 Income Tax Act | Reassessment Beyond 4 Years Void Without Fresh Tangible Material : ITAT Surat
ITAT Surat holds that reassessment proceedings under Section 147 of the Income Tax Act beyond four years from the end of the assessment year are invalid unless new tangible material justifying escapement of income is discovered. The ruling quashes reassessment orders for AY 2011-12 and 2014-15, reinforcing the limitation period for tax authorities and protecting assessees from arbitrary reopening of cases.