Objective Satisfaction Needed for Reopening Tax Assessment u/s 147; Participation Required if Initiated After Four Years.

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....Reopening of assessment u/s 147 - Reason to believe - The objective satisfaction would be sufficient for the purpose of allowing the Assessing authority to proceed with the reopening proceedings. - The reasons furnished in the case of the petitioner would be sufficient for the purpose of reopening of assessment as the case of the petitioner is initiated beyond a period of four years, but within a period of six years and therefore, the petitioner is bound to participate in the reopening proceedings for the purpose of defending their case - HC....