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2014 (2) TMI 310 - AT - Income TaxAssessment u/s 143(3) r.w.s. 147 - Held that:- The AO had reopened the assessment only on the ground that the scrutiny assessment under section 143(3) of the Act was set aside by the higher authorities - Once the assessment under section 143(3) has been annulled by the higher authorities, reopening under section 147 on that very ground would mean abuse of process of law - The annulment of assessment done under section 143(3) by the higher judicial authorities, itself, cannot be a ground for reopening - If the AO comes into the knowledge of any new material from which he has reason to believe that certain income of the assessee has escaped assessment, he can reopen the assessment - The order of CIT(A) upheld - Decided against Revenue.
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