Sec 147

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Akhil (Querist)
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27 December 2009 in section 147 it is mentioned that the AO may assess or reassess such income, other than the income involving matters which are subject matter of any appear, reference or revision, which is chargable to tax and hasescaped assessment. what does this proviso means....
Plz giv the explanation for this provisio..

Neeraj Bansal CA

Neeraj Bansal CA (Expert)
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27 December 2009 acc. to this proviso AO has the power to open all issues related to the assessment except matters which are pending at any stage of appeal or reference in relation to that a.y.

for example if AO open for a.y. 2004-05 then issues which u raised through appeal for this year and r pending at any stage then AO can not took them while doing under 147