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Reopening of assessment u/s 147 - reasons were recorded on receipt of information from Investigation Wing - Apart from this information, which has been taken as gospel truth by the AO, no independent enquiry has been made to collate and corroborate this statement and information provided by Aseem Gupta to Investigation Wing. - Assessment framed in this case is not sustainable since the very jurisdiction assumed by the AO u/s 147 of the Act is bad in law and assessment framed on the basis of “change of opinion” u/s 147/143 (3) is void ab initio - AT
Reopening of assessment u/s 147 - reasons were recorded on receipt of information from Investigation Wing - Apart from this information, which has been taken as gospel truth by the AO, no independent enquiry has been made to collate and corroborate this statement and information provided by Aseem Gupta to Investigation Wing. - Assessment framed in this case is not sustainable since the very jurisdiction assumed by the AO u/s 147 of the Act is bad in law and assessment framed on the basis of “change of opinion” u/s 147/143 (3) is void ab initio - AT
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