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Section 45, 147 & 148 of the Income Tax Act, 1961 — Reassessment — There was no effective adjudication as to what would be the effective date of Transfer while deciding the correctness of the Reassessment for the year 1996-97 while making protective assessment for the A.Y. 2001-02, thus, reassessment was valid — C Venkatachalam (HUF) vs. Assistant Commissioner of income tax [2019] 419 ITR 204 (Madras).