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2022 (11) TMI 1293 - AT - Income TaxReopening of assessment u/s 147 - reason to believe - Reopening based on audit objection and also change of opinion - HELD THAT:- Thus in view of the above discussion and case law of Hon’ble Madras High Court in the case of Cholamandalam Investment & Finance Co. Ltd.[2018 (1) TMI 146 - MADRAS HIGH COURT] that the reasons recorded in the present case are verbatim what the audit objection is. It means that the AO has not applied his independent mind to the facts of the case before recording reasons and hence, the reason merely based on audit objection cannot be a basis of reopening. Therefore, we held that reopening is bad in law and hence, the reassessment framed is quashed. Appeal filed by the assessee is allowed.
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