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2014 (7) TMI 722 - HC - Income TaxRe-assessment of proceedings u/s 147 r.w section 148 - Based on the opinion of audit party - Held that:- Mere opinion of the audit party cannot form the basis for the AO to reopen the closed assessment that too beyond four years from the end of relevant assessment year – The decision in COMMISSIONER OF INCOME TAX Versus SHILP GRAVURES LTD [2013 (11) TMI 581 - GUJARAT HIGH COURT] followed - If the reassessment proceedings are initiated merely and solely at the instance of the audit party and there was no independent application of mind by the AO with respect to subjective satisfaction for initiation of the reassessment proceedings, the notices cannot be sustained and the same deserves to be quashed and set aside – Decided in favour of Assessee.
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