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2016 (12) TMI 1663 - AT - Income TaxReopening of assessment - reasons to believe - Held that:- We hold that the Assessing Officer had no tangible material to justify his “reason to believe” that income has escaped assessment. The reassessment proceedings initiated by the Assessing Officer u/s.147 are without jurisdiction and hence, are not sustainable. Whether the DRP has power to annual assessment? - Held that:- DRP has power to adjudicate jurisdictional issues and has also has power to set aside any proposed variations. Accordingly the ground raised in the appeal by Department is dismissed.
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