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HC allowed the writ petition challenging reassessment proceedings under Section 147. The court found that the Assessing Officer (AO) lacked valid grounds for reopening the assessment, as the taxpayer had made full and true disclosure during the original proceedings. The AO failed to demonstrate independent application of mind or identify any fresh information justifying reassessment. The court observed that the AO was cognizant of all relevant facts during the initial assessment and merely relied on a subsequent year's communication without substantive evidence of concealment or incorrect information. Consequently, the reassessment order was quashed as procedurally invalid and without reasonable basis.
HC allowed the writ petition challenging reassessment proceedings under Section 147. The court found that the Assessing Officer (AO) lacked valid grounds for reopening the assessment, as the taxpayer had made full and true disclosure during the original proceedings. The AO failed to demonstrate independent application of mind or identify any fresh information justifying reassessment. The court observed that the AO was cognizant of all relevant facts during the initial assessment and merely relied on a subsequent year's communication without substantive evidence of concealment or incorrect information. Consequently, the reassessment order was quashed as procedurally invalid and without reasonable basis.
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