#Section 147
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While granting sanction u/s 151, application of mind is sacrosanct
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Reopening on incoherent reasons not valid u/s 147
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Reassessment u/s 147 not permissible merely on change of opinion: ITAT
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Validity of reopening of assessments
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Powers of the A.O. are not plenary or unbridled
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AO issuing original assessment order can only initiate reopening proceedings
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HC restricts remedial action on audit objection – tones down rigour of Instruction No. 9/2006
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No Reopening of Assessment to be made on Audit Objections: Committee Recommends
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Reassessment not valid on mere information of investigation wing as no direct nexus establishes with income escapement
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Reassessment proceedings could not be declared as null and void where AO was prompted by correct information
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Mere reason to believe that income has escaped assessment not sufficient to reopen assessments beyond 4 years
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No new addition can be made in reopening on issue duly considered during original proceeding
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Reasons to reopen assessment must be tangible & should not merely be based on Investigation wing’s report
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