Validity of reopening of assessment - Validity of multiple...

Validity of reopening of assessment - Validity of multiple notices issued under various sections of the Income Tax Act, particularly targeting the application of Section 50C to a buyer rather than a seller. - Section 50C applies only to sellers and not buyers. It was held that there was a non-application of mind in issuing the order under Section 148A(d), as the authorities failed to recognize this distinction. Furthermore, the court rejected the respondent's explanation of 'human error' and emphasized that issuing authorities must thoroughly apply their minds before sanctioning such notices. The petition was allowed, leading to the quashing of the impugned notices. - HC

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