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Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
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