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Section 147: Taxpayer's Right to Contest Hinges on AO's Detailed Documentation and Communication of Reopening Reasons.
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....Reopening of assessment u/s 147 - The entire exercise of re-opening would depend upon the reasons recorded by the AO and therefore the reasons recorded to re-open the assessment by the AO must disclose all relevant facts to the assessee so as to refute the reasons by filing objections. Unless the AO records his independent satisfaction in the reasons recorded on the basis of the information received and communicates the same to the assessee, right of the assessee to file objections would remain an empty formality. - HC....