Writ Petition Can't Challenge Assessment Reopening u/s 147; Procedural Issues Addressed in Reassessment Process.

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....Reopening of assessment u/s 147 - objections in reassessment proceedings - whether violation of procedures since the reopening of the assessment proved ? - correctness of the reasons set out by the JCIT, and the rejection of objections raised by the respondent by order by the 2nd appellant, can be decided during the re-assessment proceedings and not in the writ. - HC....