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HC invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
HC invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
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