Court Rules No Valid Basis for Reopening Assessment u/s 147; Payment Not Considered Penalty u/s 37(1.

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....Reopening of assessment u/s 147 - reason to believe - Claim of deduction on account of payment made to settle a class action suit - AO observed the same as in the nature of penalty and proposed to disallow u/s 37(1) - A.O. had no reason to believe that the payment made towards settlement of the class action suit was a payment towards a penalty imposed and on that account we hold that there was no reason for the A.O. to believe that income had escaped assessment. - HC....