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High Court Sets Aside Reopening of Assessment u/s 147 Due to Inconsistency and Lack of Justification.
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....Reopening of assessment u/s 147 - doctrine of res judicata - principal of consistency - Consistency does not mean putting iron fetters on the subsequent decision making; it only means expecting that a deviation from the previous decision in similar set of circumstances is explained by way of cogent and rational reasons. In the present case, the decision taken first in point of time (order dated 28.07.2022) was a reasoned decision, based on the analysis of material on record, but the decision taken subsequently (order dated 31.07.2022) not just took a view completely inconsistent with the previous view but even without an iota of reason. - notice cannot sustain and set aside - HC....