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High Court Rules Reopening Tax Assessment u/s 147 Invalid; AO's Roving Inquiry Deemed Impermissible.
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....Reopening of assessment u/s 147 - AO issued notice under section 148 of the Act only to make a roving inquiry into the facts which were already considered by the Assessing Officer at the time of framing the original assessment under section 143(3) of the Act. It appears that the Assessing Officer now wants to re-verify the facts which is not permissible to be an acceptable ground for exercising powers to reopen the assessment. - HC....