High Court Criticizes ITAT for Quashing Section 147 Notice Without Examining Facts, Cites Peass Industrial Engineers Case.

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....Reopening of assessment u/s 147 - unexplained cash credit - ITAT quashed the notice - Unfortunately, the tribunal failed to examine any of the factual details which have been brought out by the AO as well as the CIT(A) but merely went on the basis as to what are the conditions to be fulfilled in order to reopen the assessment. As pointed out earlier, reasons given by the learned tribunal to distinguish the decision in Peass Industrial Engineers is not tenable. - HC....