Court Questions PCIT's Application of Mind in Reopening Assessment; Matter Sent Back for Reconsideration u/s 147.

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....Reopening of assessment u/s 147 - application of mind by the PCIT while granting sanction u/s 151 - validity of order disposing objections questioned - PCIT has simply endorsed “Yes”. No date is mentioned and it does not also disclose why he felt there was a need to grant the sanction. None of these points have been discussed in the order disposing the objections - Matter restored back before the AO for denovo consideration - HC....