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2020 (11) TMI 98 - HC - Income TaxReopening of assessment - contention raised by the assessee that the Assessing Officer has done a roving enquiry by re-examining the facts already in record - HELD THAT:- Though such a ground was raised, the Tribunal in Paragraph No.3 of the impugned order, records that only two grounds have been raised by the assessee. When a specific plea has been raised by the assessee, contesting the validity of the reopening proceedings, the CIT(A) and the Tribunal could have considered the same As noticed above, the assessee has specifically raised a plea regarding the validity of the reopening. Infact, the assessee being a Nationalized Bank, does not stand to gain by not raising such a plea, especially when they have got a large team of Legal Experts and Chartered Accountants advising them in these matters. Therefore, the validity of the reopening needs to be considered by the Tribunal on merits and in accordance with law - matter is remanded to the Tribunal to decide the validity of the reopening proceedings.
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