Reassessment Requires Fresh Review: Section 147 Case Nullifies Original Proceedings Without Initial Assessment Order.

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....Reopening of assessment u/s 147 - no original assessment order in the case of the assessee passed - Even assuming for the sake of argument that if an intimation under Section 143(1) of the Act is considered to be an order of assessment, in the subsequent re-assessment proceeding, the original assessment proceeding get effaced and the AO was required to consider the proceeding de novo and to consider the claim of the assessee. - HC....