Bank Challenges Reopening of Tax Assessment u/s 147; Court Considers Premature to Form Opinion on Objections.

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....Reopening of assessment u/s 147 - The argument that the objections have not been considered may not hold water as the annexure does deal with the crux of the objections but it may be too early a stage in the proceedings to express any opinion on this aspect of the mater. As rightly pointed out by learned Revenue Counsel, reassessment notice under Section 148 of IT Act i.e, impugned notice if carried to its logical end, in the facts and circumstances of the case, will clearly neutralize all these arguments and the writ petitioner assessee bank will not be aggrieved in any manner. - HC....