Reopening notices upheld, objections allowed in reassessment proceedings.

The High Court upheld the reopening of assessment notices, rejecting the petitioner's arguments. It determined that alleged cash receipt issues were not examined during the original assessment as the information came to light afterward through the CBDT's Risk Management Strategy. The reopening was not based on an erroneous claim of no return filed. The approval under section 151 was deemed thoughtful, considering the material and information. The court found no grounds to quash the reopening notices; however, the petitioner retains the right to raise objections during reassessment or appellate proceedings. .....

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