Reopening Tax Assessment After 4 Years Requires Genuine Consideration and Satisfaction Recording as per Section 151.

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....Validity of reopening of assessment u/s 147 - assessment beyond a period of 4 years - mandation of recording satisfaction - The satisfaction as contemplated u/s 151 of the Act is not an empty formality as the authorities have to apply their mind and record satisfaction. When the authorities were not oblivious to the date of proposal then it cannot be said that they have applied their mind or considered the proposal of the AO in its right earnest. - AT....