Section 147 Allows New Grounds for Reassessment; Article 226 Cannot Block This Process in Income Tax Cases.

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....Reopening of assessment u/s 147 - if in the course of such reassessment, the 2nd respondent assessing officer finds any other reasons for justifying reopening of the assessment on some other point, he may do so. Such exercise cannot be stifled under Article 226 of the Constitution of India. - HC....