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2021 (6) TMI 914 - MADRAS HIGH COURTReopening of assessment u/s 147 - Reassessment beyond the period of four years - HELD THAT:- What is required is to scrutinize the reasons and sufficiency of the reasons need not be gone into by the High Court in a writ proceedings where the assessment is sought to be reopened by invoking Section 147 - Thus, sufficiency of the reasons cannot be gone into in a writ proceedings. High Court cannot conduct a rowing enquiry in respect of the accounts details as well as the technicalities involved in respect of the transactions. All those aspects are to be considered by the AO while passing the final order of reassessment. Perusal of the above findings of the 3rd respondent would be sufficient to hold that the requirements of Section 147 of the Act has been complied with and the initiation of reopening proceedings is well within the provisions of the Act and therefore, the respondents are at liberty to proceed with re-assessment by following the procedures and by affording opportunity to the writ petitioner/assessee, as contemplated. The respondents are directed to complete the said exercise of completion of the re-assessment proceedings within a period of four months from the date of receipt of a copy of this order.
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