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The HC rejected the petitioner's submissions and held: The issue of alleged cash receipt was not examined during regular assessment proceedings as the information was received after conclusion of assessment. The reopening is based on information under CBDT's Risk Management Strategy, not on the erroneous statement that no return was filed. The approval u/s 151 is not without application of mind as remarks show consideration of material and information. No reason to quash the reopening notices, but petitioner can raise objections in reassessment/appellate proceedings.
The HC rejected the petitioner's submissions and held: The issue of alleged cash receipt was not examined during regular assessment proceedings as the information was received after conclusion of assessment. The reopening is based on information under CBDT's Risk Management Strategy, not on the erroneous statement that no return was filed. The approval u/s 151 is not without application of mind as remarks show consideration of material and information. No reason to quash the reopening notices, but petitioner can raise objections in reassessment/appellate proceedings.
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