Court Rules on Reopening Tax Assessment u/s 147: Original Facts Not Re-examined, Engage in Reassessment Process.

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....Validity of reopening of assessment u/s 147 - This Court cannot go into the factual details now furnished by the petitioner at the time of original assessment nor made a comparison with reference to the original explanations or submissions along with inferences drawn by the Assessing Officer for reopening of assessment. - the petitioner has to participate in the process of re-assessment and establish their case in the manner known to law and by availing the opportunities to be provided by the respondent. - HC....