Section 147: Reopening Assessment on Penny Stocks Hinges on Differentiating "New Ground" vs. "New Reasons" with Due Diligence.

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....Reopening of assessment u/s 147 - penny stock purchases - “new ground” v/s “new reasons” - We take the notice of the fact that, the copy of the approval has been provided to the assessee at the stage of passing the order of disposing the objections raised by the assessee. Therefore, it is evident that, in the instant case, the authorities concerned have given approval after due application of mind and expressed their satisfaction with regard to the reasons recoded for reopening of the assessment. - HC....