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The HC quashed the reopening under s.147/s.148, holding that the reasons to believe relied upon for reassessment had already been considered by the AO in the original assessment order. The court found no fresh material justifying exercise of the re-assessment jurisdiction and reiterated that the AO cannot review or revisit his earlier assessment to reexamine documents or evidence already placed before him. Consequently the reopening notice and resultant proceedings were set aside and the original assessment upheld in favour of the assessee, with the revenue precluded from initiating reassessment merely to obtain a second look at material previously considered.
The HC quashed the reopening under s.147/s.148, holding that the reasons to believe relied upon for reassessment had already been considered by the AO in the original assessment order. The court found no fresh material justifying exercise of the re-assessment jurisdiction and reiterated that the AO cannot review or revisit his earlier assessment to reexamine documents or evidence already placed before him. Consequently the reopening notice and resultant proceedings were set aside and the original assessment upheld in favour of the assessee, with the revenue precluded from initiating reassessment merely to obtain a second look at material previously considered.
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