#Section 147
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Reopening of Assessments Section 147 w.e.f. 01.04.2021
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AO cannnot review assessment order-Reassessment order quashed
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Mere change of opinion not valid for reopening of assessment u/s 148
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Invocation of jurisdiction u/s 263 on same subject which was duly verified in reassessment proceeding unjustified
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Original assessment completed after considering all facts hence re-assessment unsustainable
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Borrowed Satisfaction & Necessity of Providing Material to Assessee before Reopening An Assessment
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Extended time under TOLA not available for Sanction by Specified Authority U/S 151
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Reopening by merely quoting Insight portal information is invalid
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Draft submission regarding approval u/s 151 from competent authority for issue of notice u/s 148
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Reassessment proceedings without any new tangible material is unsustainable in law
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Another Reassessment Notice Cannot be Issued by AO for Same AY
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Reasons for reopening found to be non-existent, such defect is not curable by applying section 292B
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Reassessment proceedings invalid as no failure in disclosing any material facts
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