Assessment u/s 147 of Income Tax Act cannot be made without a Substantive Assessment: ITAT

Assessment u/s 147 Requires Substantive Assessment: The Income Tax Appellate Tribunal (ITAT) ruled that assessments made under Section 147 of the Income Tax Act, 1961, must have a substantive basis and cannot be done solely on protective grounds. The case involved a mining contractor whose assessment was reopened, and the tribunal found that without a concrete substantive assessment, the proceedings lacked validity. The decision reiterates the importance of thoroughness in tax reassessment procedures.