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of The case involves the validity of reopening assessment u/s 147 of the IT Act. The Assessing Officer must have 'reasons to believe' as per the statutory scheme. The court emphasized the need to provide all information to the assessee for defense. Adjudication on information available with AO not required at the stage of passing order u/s 148A(d). The merits of the information are subject to appeal u/s 246A. The petitioner claimed no knowledge of sale by power of attorney holder, but the court held that the petitioner is bound by the actions of the power of attorney holder. The High Court's jurisdiction under Article 226 is for public law remedy. The court dismissed the writ petition.
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