2019 (2) TMI 1330

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....TICE HARSHA DEVANI) 1. Mr.Tushar Hemani, learned advocate for the petitioner has invited the attention of the Court to the order dated 20.12.2018 passed by this Court in the case of Vijya Laxmi Exports in Special Civil Application No.20132 of 2018 to submit that in the case of the partnership firm also, the Assessing Officer sought to reopen the assessment on the ground that the firm had claimed....

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....ch is also reflected in clause (g) in column No.17 in the statement of particular required to be furnished under Section 44AB of the Act. It was submitted that therefore, the Assessing Officer seeks to reopen the assessment on the basis of conjectures and surmises and that on the reasons recorded, the Assesing Officer could not have formed the belief that income chargeable to tax has escaped asses....