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Income Tax - Highlights / Catch Notes

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Validity of Reopening of assessment u/s 147 - When the primary ...

Case Laws     Income Tax

November 23, 2023

Validity of Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion to commence proceedings for reassessment. Even if the AO, who passed the assessment order, may have raised too many legal inferences from the facts disclosed, on that account the AO, who has decided to reopen assessment, is not competent to reopen assessment proceedings. - HC

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