Section 147, 148 of Income tax Act, 1961— Reassessment u/s 147 /148— This petition challenges the order passed by the respondent, by the impugned order respondent has dropped the assessment proceedings initiated under Section 147 of the Act.

It is the grievance of the petitionmer that once the Assessing Officer has issued a notice for reassessment under Section 147/148 of the Act and the assessee has not opposed the same, then it is not open to the Assessing Officer to drop the same. This dropping of proceedings, the petitioner submits is not permissible.

Held that—in case of K. Sudhakar S. Shanbhag Vs. Income Tax Officer (2003) 126 Taxman 476  this Court has held that dropping of re-assessment proceedings by the Assessing Officer under Section 147 of the Act, even in the absence of the assessee challenges the notice under Section 147/148 of the act, is justified. This Court emphasized that the proceedings for reassessment under Section 147 of the Act is for the benefit of the Revenue.[MENCK GMBH VERSUS ASSISTANT COMMISSIONER OF INCOME – TAX AND ANR.] [2019] 16 ITCD Online (25) [ BOMBAY HIGH COURT]