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The HC dismissed the petition challenging the reopening of assessment under section 147, finding no violation of natural justice or jurisdictional error. The Court held that the reopening proceedings under section 148A are limited in scope and do not amount to a full reassessment. The authority's inference doubting the source of funds for property purchase was based on material considered after giving the petitioner an opportunity to reply. The writ jurisdiction under Article 226 does not extend to reappraising factual findings or substituting the Court's view for the Assessing Officer's. The Court emphasized that the validity of reopening depends on the decision-making process, which was found proper here. The petitioner was directed to present all explanations before the Assessing Officer during assessment. No interference was warranted; thus, the writ petition was dismissed.
The HC dismissed the petition challenging the reopening of assessment under section 147, finding no violation of natural justice or jurisdictional error. The Court held that the reopening proceedings under section 148A are limited in scope and do not amount to a full reassessment. The authority's inference doubting the source of funds for property purchase was based on material considered after giving the petitioner an opportunity to reply. The writ jurisdiction under Article 226 does not extend to reappraising factual findings or substituting the Court's view for the Assessing Officer's. The Court emphasized that the validity of reopening depends on the decision-making process, which was found proper here. The petitioner was directed to present all explanations before the Assessing Officer during assessment. No interference was warranted; thus, the writ petition was dismissed.
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