Reassessment Blocked: Section 147 Cannot Override Original Assessment with Conscious Application of Mind Without New Information.

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....Reopening of assessment u/s 147 - addition u/s 40(a)(ia) - If there is conscious application of mind on an issue during assessment, and this Court as in the circumstances of the case has already opined that there was such conscious application of mind and therefore a deemed opinion, there cannot be reassessment only because of an error in such opinion. The reasons offered by the A.O to justify reassessment cannot be accepted as an objective view based on any subsequent information in the absence of necessary material in this regard. - HC....