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The central issue was the validity of reopening assessment under Section 147 read with Sections 148 and 148A: the Court held that reopening requires "tangible material" and a rational connection between that material and the Assessing Officer's opinion of escapement, following Lakhmani Mewal Das; absent such nexus the action is unlawful. The Court found arbitrariness in changing the ground of reopening from the show-cause notice and a consequent breach of natural justice, and emphasized that Section 147 operates only after completion of the Section 148/148A drill. The order under Section 148A(3) and the Section 148 notice for AY 2019-20 were set aside. - HC
The central issue was the validity of reopening assessment under Section 147 read with Sections 148 and 148A: the Court held that reopening requires "tangible material" and a rational connection between that material and the Assessing Officer's opinion of escapement, following Lakhmani Mewal Das; absent such nexus the action is unlawful. The Court found arbitrariness in changing the ground of reopening from the show-cause notice and a consequent breach of natural justice, and emphasized that Section 147 operates only after completion of the Section 148/148A drill. The order under Section 148A(3) and the Section 148 notice for AY 2019-20 were set aside. - HC
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