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The High Court quashed the impugned notice u/s 148 for reopening of assessment. It held that since the petitioner had not directly received any remittances from the DSNE CGHS, there was no occasion for the petitioner to make a disclosure in its Return of Income. Consequently, the reason to believe for invoking Section 147 for reassessment was unsustainable. However, the Court left it open to the respondents to initiate proceedings afresh, if otherwise permissible in law.
The High Court quashed the impugned notice u/s 148 for reopening of assessment. It held that since the petitioner had not directly received any remittances from the DSNE CGHS, there was no occasion for the petitioner to make a disclosure in its Return of Income. Consequently, the reason to believe for invoking Section 147 for reassessment was unsustainable. However, the Court left it open to the respondents to initiate proceedings afresh, if otherwise permissible in law.
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