Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reopening of assessment u/s 147 - Writ jurisdiction of this Court under Article 226 of the Constitution of India or supervisory jurisdiction of this Court under Article 227 of the Constitution of India cannot be invoked to attack the sufficiency of the reasons assigned for re-opening of a case of escaped income so long as the power exercised and the reasons assigned therefore are traceable to any statutory provision. Thus, it cannot be said that the impugned notice of the assessment and re-opening of the case u/s 147 of the IT Act is bereft of jurisdiction. - HC
Reopening of assessment u/s 147 - Writ jurisdiction of this Court under Article 226 of the Constitution of India or supervisory jurisdiction of this Court under Article 227 of the Constitution of India cannot be invoked to attack the sufficiency of the reasons assigned for re-opening of a case of escaped income so long as the power exercised and the reasons assigned therefore are traceable to any statutory provision. Thus, it cannot be said that the impugned notice of the assessment and re-opening of the case u/s 147 of the IT Act is bereft of jurisdiction. - HC
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