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2019 (11) TMI 137 - ITAT DELHIReopening of assessment u/s 147 - assessment has been reopened solely on the basis of information received from Pr. DIT(Inv.), Ahmedabad - Non independent application of mind - HELD THAT:- Assessment has been carried away by the report of the investigation wing without making any independent verification to justify the reopening. The Hon’ble High Court of Bombay in the case of Coronation Agro Industries Ltd. vs DCIT [2017 (1) TMI 904 - BOMBAY HIGH COURT] had an occasion to consider an identical issue with identical set of facts has held that notice u/s 148 of the Act is without jurisdiction Reasons recorded for reopening of the assessment are devoid of any independent application of mind by the AO and therefore, the notice issued u/s 148 of the Act deserves to be quashed. - Decided in favour of assessee.
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