Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had...

Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had not challenged the order of the CIT (A) annulling the re-assessment proceedings is not a mere ‘technical approach’ - there was no basis for the re-opening of the assessment except the presumptive observation of the Revenue audit which itself was not based on any tangible material - no substantial question of law arises .....

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