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    <title>2019 (4) TMI 1472 - ITAT DELHI</title>
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    <description>Reassessment under s.147 was challenged on the ground that the AO failed to furnish recorded reasons within a reasonable time and, after objections were filed, did not dispose them by a speaking order before completing assessment under s.143(3) r/w s.147. The ITAT held that non-supply of reasons for an extended period and failure to pass a reasoned order on objections violated the mandatory procedure and caused prejudice by depriving the assessee of an effective opportunity to challenge the reopening before a higher forum. Consequently, the reassessment proceedings were quashed, and the appellate authority&#039;s finding upholding reopening was set aside.</description>
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      <title>2019 (4) TMI 1472 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=379028</link>
      <description>Reassessment under s.147 was challenged on the ground that the AO failed to furnish recorded reasons within a reasonable time and, after objections were filed, did not dispose them by a speaking order before completing assessment under s.143(3) r/w s.147. The ITAT held that non-supply of reasons for an extended period and failure to pass a reasoned order on objections violated the mandatory procedure and caused prejudice by depriving the assessee of an effective opportunity to challenge the reopening before a higher forum. Consequently, the reassessment proceedings were quashed, and the appellate authority&#039;s finding upholding reopening was set aside.</description>
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