Section 147: Reopening Assessment Void if "Reason to Believe" Fails Judicial Scrutiny, Even Without Initial Objection.

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....Reopening of assessment u/s 147 - objections regarding reason to believe raised first time at appellate stage - If reasons recorded upon being challenged at any stage of proceedings falls to withstand the test of judicial scrutiny, in that eventuality, upon such recorded reasons no valid notice can be issued and any assessment framed consequent thereto even taking shelter of ‘no objection’ from the assessee could save the assessment from being held to be declared void-ab-initio and the objection of Revenue was rejected. - AT....