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HC dismissed writ petition challenging reopening of assessment under s.147. Petitioner failed to provide crucial attachments and documentary evidence to support claims regarding prior disclosure during regular assessment. Court held it could not exercise extraordinary jurisdiction to investigate factual matters without complete documentation. While audit objection formed basis for reopening, Court refrained from deciding broader legal question of post-amendment reopening validity based on audit opinions. Petitioner retains liberty to challenge validity of reassessment before Appellate Authority after final order under s.148. Matter involves factual verification inappropriate for writ proceedings.
HC dismissed writ petition challenging reopening of assessment under s.147. Petitioner failed to provide crucial attachments and documentary evidence to support claims regarding prior disclosure during regular assessment. Court held it could not exercise extraordinary jurisdiction to investigate factual matters without complete documentation. While audit objection formed basis for reopening, Court refrained from deciding broader legal question of post-amendment reopening validity based on audit opinions. Petitioner retains liberty to challenge validity of reassessment before Appellate Authority after final order under s.148. Matter involves factual verification inappropriate for writ proceedings.
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