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2020 (11) TMI 315 - AT - Income TaxReopening of assessment u/s 147 - validity of reasons to believe - HELD THAT:- Reasons recorded by the Assessing Officer is based on presumption and without application of mind by stating therein that assessee has not filed its return of income whereas the evidences produced by the assessee in the shape of paper book before the CIT(A) as well as before the Tribunal, establish that the assessee has filed the return of income for the assessment year in dispute, hence, decision of RMG Polyvinyl [2017 (7) TMI 371 - DELHI HIGH COURT] is squarely applicable here and therefore, applying the said ratio, the reassessment in the present case is bad in law and accordingly quashed and appeal of the assessee is allowed.
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