High Court: Consistent Standard for "Reason to Believe" in Tax Reassessments u/ss 147, 143(3), and 143(1).

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....Reassessment u/s 147 – the expression “reason to believe“ cannot have two different standards or sets of meaning, one applicable where the assessment was earlier made u/s 143(3) and another applicable where an intimation was earlier issued u/s 143(1) - HC....