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of <h1>Delhi HC dismisses appeal challenging reopening of assessment under Section 147.</h1> The Delhi HC allowed the application and disposed of it. The appeal questioned the AO's application of mind in re-opening the assessment under Section ... Validity of re-opening of assessment u/s 147 - eligible reasons to believe - Held that:- As pointed out rightly by the ITAT in the impugned order, there was no application of mind by the AO when he issued notice under Section 148 - AO was also not aware that the Assessee had filed a return for the AY in question. No satisfaction was also been recorded by the ACIT. In the circumstances, the conclusion of the ITAT suffers from no legal infirmity. No substantial question of law arises. The Delhi High Court allowed the application and disposed of it. The appeal questioned whether the AO applied his mind in re-opening the assessment under Section 147, but the ITAT found no application of mind by the AO. The appeal was dismissed as no substantial question of law arose.
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