High Court Sets Aside ITAT Order on Reopening Assessment u/s 147 Over Gupta House Property Classification Dispute.

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....Reopening of assessment u/s 147 - deduction u/s 54 - allegation that thee property which was named as 'Gupta House' was actually an 'industrial plot' and not a 'residential house' - as per the Tribunal the AO did not have 'reasons to believe' that income chargeable to tax had escaped assessment - order of the ITAT set aside - HC....