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The HC invalidated the reassessment proceedings under Section 147, finding no tangible material indicating escaped income. The court determined that the Assessing Officer merely reconsidered the same material that had already undergone scrutiny during the original assessment, where Section 10A deductions were already reduced from the claimed amount. The reasons furnished for reopening failed to demonstrate any failure by the assessee to disclose true and full material facts-a prerequisite under Section 147. The court concluded that the reassessment constituted an impermissible change of opinion rather than discovery of new information, as no new material or undeclared income was identified that wasn't available during the original assessment process.
The HC invalidated the reassessment proceedings under Section 147, finding no tangible material indicating escaped income. The court determined that the Assessing Officer merely reconsidered the same material that had already undergone scrutiny during the original assessment, where Section 10A deductions were already reduced from the claimed amount. The reasons furnished for reopening failed to demonstrate any failure by the assessee to disclose true and full material facts-a prerequisite under Section 147. The court concluded that the reassessment constituted an impermissible change of opinion rather than discovery of new information, as no new material or undeclared income was identified that wasn't available during the original assessment process.
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