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of Validity of re-opening of assessment u/s 147 - Procedure of recording satisfaction for reopening assessment - notice beyond period of four years - The ITAT observed that, in the income tax return assessee has disclosed long term capital gain, but AO in the reasons recorded has mentioned short term capital gain/loss which means that he was not sure of the transactions for which the reopening is carried out. Further, AO has mentioned the figure as long term capital gain/short term capital loss. This observation is also factually incorrect. - The ITAT held that the re-opening of assessment u/s 147 was invalid due to non-compliance with procedural requirements and lack of independent application of mind by the AO.
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