High Court Quashes Reassessment Notice u/s 147; AO's Later Discovery of Irregularity Insufficient for Reopening.

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....Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain irregularity in the claim by itself would not be sufficient to satisfy requirements of the proviso to Section 147 - It is possible that the specific angle of the depreciation earlier claimed to be set off against the income of the current year of the eligible business may not have been in the mind of the Assessing Officer. - Notice quashed - HC....