https://www.taxtmi.com/caselaws?id=449012 The HC set aside the reopening of assessment u/s 147 based on audit objections. The court found that during original assessment proceedings, the AO had issued detailed notices u/s 142(1) requiring comprehensive documentation and explanations regarding various disallowances including u/s 14A. The assessee provided detailed replies and assessment was completed with specific disallowances. Since the grounds for reopening were already considered during original assessment and the assessee had made full disclosure of primary facts, the reopening was impermissible under the proviso to Section 147. The court emphasized that AO cannot merely rely on audit objections without independent evaluation. en-us Mon, 29 Jan 2024 00:00:00 +0530 Mon, 20 Jan 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449012 The HC set aside the reopening of assessment u/s 147 based on audit objections. The court found that during original assessment proceedings, the AO had issued detailed notices u/s 142(1) requiring comprehensive documentation and explanations regarding various disallowances including u/s 14A. The assessee provided detailed replies and assessment was completed with specific disallowances. Since the grounds for reopening were already considered during original assessment and the assessee had made full disclosure of primary facts, the reopening was impermissible under the proviso to Section 147. The court emphasized that AO cannot merely rely on audit objections without independent evaluation. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449012