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High Court Finds Non-Application of Mind by Assessing Officer in Reopening Assessment u/s 54 Due to Clear Disclosures.
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....Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC....