Reassessment u/s 147 Can't Rely on Internal Audit Opinions, Courts Rule Against Audit-Based Reassessment Notices.

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....Reopening of assessment u/s 147 - It is settled law that the opinion of the Internal Audit party of the Income Tax Department cannot be recorded as information within the meaning of section 147(b) of the Act for the purpose of opening the assessment. The courts have also held that notice of reassessment cannot be issued based on information received from audit objection - HC....