Reopening tax assessments u/s 147 is invalid if a Settlement Commission order exists, unless fraud is involved.

Reassessment u/s 147 - existence of Settlement Commission order in the relevant AY - concluded assessment by Settlement Commission u/s 245D(4) can only be reopened in case of fraud or misrepresentation of facts, as per section 245D(6) - the assumption of jurisdiction u/s 147 is invalid and without authority of law irrespective of sufficient material for the AO to form the belief for escaped assessment .....

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