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    <title>Tax Reassessment Quashed: Court Finds Reopening Lacked Valid Reason, Cites AO&#039;s Failure in Addressing Objections.</title>
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    <description>Reopening of assessment - The High Court held that no case for reason to believe was made out by the AO. They observed a lack of application of mind in the reasons recorded for reopening the assessment. It was noted that the information relied upon by the AO contained inaccuracies, indicating a non-application of mind. - The Court found that the AO did not address the factual positions asserted by the petitioner in their objections, further indicating a lack of proper consideration. - Ultimately, the Court concluded that the reassessment proceedings were initiated on incorrect facts and lacked jurisdiction, thus quashing the impugned notices and order.</description>
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      <title>Tax Reassessment Quashed: Court Finds Reopening Lacked Valid Reason, Cites AO&#039;s Failure in Addressing Objections.</title>
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      <description>Reopening of assessment - The High Court held that no case for reason to believe was made out by the AO. They observed a lack of application of mind in the reasons recorded for reopening the assessment. It was noted that the information relied upon by the AO contained inaccuracies, indicating a non-application of mind. - The Court found that the AO did not address the factual positions asserted by the petitioner in their objections, further indicating a lack of proper consideration. - Ultimately, the Court concluded that the reassessment proceedings were initiated on incorrect facts and lacked jurisdiction, thus quashing the impugned notices and order.</description>
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