#Section 147
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Validity of reopening of assessment has to be determined on the basis of reasons for reopening
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Reopening Reasons to believe must be based on new tangible materials
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Power to reassess cannot be exercised on the basis of mere change of opinion
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Mere Retracted statement cannot form the basis of reopening
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Notice U/s. 148 notice and order on objections cannot be challenged by Writ Petition
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Re-assessment proceedings based on mere bald statement that assessee has failed to make a full & true disclosure of material facts not sufficient
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If no additions made on grounds of reassessment, than no addition can be made on other aspects
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Reassessment cannot be challenged based on mere subsequent judgment in the case of another assessee
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S. 147 Disclosure of 2G Spectrum Report not mandatory, if AO Furnished material on which he recorded his satisfaction
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Explanation 3 to section 147 has no application In relation to issue cropped up subsequent to original assessment on new set of facts
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Quality & lavishness of construction is not incriminating material
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Re-appreciation of seized material in subsequent proceedings by the AO is unjustified
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Return of income processed u/s 143(1) cannot be reassessed u/s 147 on mere change of opinion of AO
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