Court Rules on Reopening Assessment: No "Reasons to Believe" u/s 147; Favors Assessee in Section 14A Case.

Validity of Reopening of assessment u/s 147 - eligibility of reasons to believe - change of opinion - Disallowance u/s 14A r.w.r. 8D - As in this case, it is not even prima facie the case of the Assessing Officer that there was failure on part of petitioner to fully and truly disclose all material facts, this Court has to interfere by exercising its jurisdiction under Article 226 of the Constitution of India. - Decided in favour of assessee. - HC .....

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