Reopening based on mere Shah Commission Report not Valid if no Application of Mind by AO

Sesa Sterlite Ltd. Vs ACIT (Bombay High Court at Goa)

Section 147 : Reassessment-After the expiry of four years-Shah Commission’s report- Cash credit -Under-invoicing -Merely on basis of Shah Commission’s Report opining that there was under-invoicing of export price by iron-ore miners and exporters, reassessment could not be initiated when there was nothing to indicate that any particular income had accrued to anyone as a result of price difference-Notice based on report of commission is

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