Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Reopening of assessment u/s 147 - No new information was received by the Assessing Officer at the time of initiation of reassessment proceedings, and it was merely a fresh application of mind to the same set of facts as were available at the time of original scrutiny assessment proceedings. - the reopening of assessment under section 147 of the Act, in the present case, is bad in law and therefore is set aside. - AT
Reopening of assessment u/s 147 - No new information was received by the Assessing Officer at the time of initiation of reassessment proceedings, and it was merely a fresh application of mind to the same set of facts as were available at the time of original scrutiny assessment proceedings. - the reopening of assessment under section 147 of the Act, in the present case, is bad in law and therefore is set aside. - AT
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