Reopening Tax Assessment u/s 147 Challenged; Appellant Free to Present Arguments to First Appellate Authority.

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....Validity of reopening of assessment u/s 147 - if the appellant is to be relegated to pursue the appellate remedy, all such findings needs to be vacated, otherwise it would tantamount to putting fetters on the exercise of the powers of the appellate remedy which should not be done. Thus, all issues are left open and the appellant is at liberty to canvas all factual and legal issues before the First Appellate Authority which shall be considered and decided by the First Appellate Authority in accordance with law. - HC....