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Validity of Reopening of assessment based on order passed u/s 263 - The Court found that the reassessment proceedings lacked the satisfaction of jurisdictional pre-conditions and were based solely on an order that had been set aside by the Income Tax Appellate Tribunal. Therefore, the notices and order issued by the Assessing Officer to reopen the assessment could not be sustained. The Court emphasized that once a query is raised during the assessment proceedings and answered by the assessee, it is deemed to have been considered and accepted by the Assessing Officer.
Validity of Reopening of assessment based on order passed u/s 263 - The Court found that the reassessment proceedings lacked the satisfaction of jurisdictional pre-conditions and were based solely on an order that had been set aside by the Income Tax Appellate Tribunal. Therefore, the notices and order issued by the Assessing Officer to reopen the assessment could not be sustained. The Court emphasized that once a query is raised during the assessment proceedings and answered by the assessee, it is deemed to have been considered and accepted by the Assessing Officer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
