2024 (5) TMI 755

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..... ed assessment - HELD THAT:- Revenue could hardly dispute that the NFAC s lower appellate discussion has reproduced the said reopening reasons making it clear that the alleged income required detailed verification as well as in-depth enquiry is needed for which the case is reopened Faced with this situation, the undersigned is of the considered opinion in light of Manzil Dinesh Kumar Shah, [ 2018 ( .....

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..... issue herein is that of validity of the impugned reopening/reassessment itself wherein the learned Assessing Officer had recorded his reasons to believe that the taxpayer s corresponding taxable income arising from sale of immovable property; had escaped assessment. The Revenue could hardly dispute that the NFAC s lower appellate discussion in para 4.1 at page-4 has reproduced the said reopening .....

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