Reassessment u/s 147 Invalid as Tribunal Previously Rejected Reasons; Current Assessment Order Quashed.

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....Reopening of assessment u/s 147 - Since the present assessment order is framed on the very same reasons, which were considered by the Tribunal (supra) while quashing the order, once the reasons have not been accepted by the Tribunal, the same cannot be held to be good for the present assessment. - AT....