Validity of Reopening of assessment u/s 147 - reason to believe...

Validity of Reopening of assessment u/s 147 - reason to believe - Reply of the assessee through reproduced but the contents thereof are not even referred or analyzed prima facie - The High Court observed that the Assessing Officer had not adequately considered the evidence presented by the petitioner in response to the notice. According to Section 148A(d) of the Income Tax Act, the Assessing Officer is required to decide the validity of issuing a notice based on the material available, including the assessee's reply. However, in this case, the Assessing Officer's decision seemed to ignore the petitioner's evidence.

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