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Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
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