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2021 (7) TMI 220 - AT - Income TaxValidity of reopening of assessment u/s 147 - Non follow of procedure laid down - HELD THAT:- Recording of reasons and furnishing of the same has to be strictly complied with as it is a jurisdictional issue and in the absence of reasons being furnished when sought for would make an order passed on reassessment bad in law. We also find that in the case of Jayanthi Natarajan [2017 (9) TMI 1042 - MADRAS HIGH COURT]has held that when the procedure required to be followed has not been adhered to, the entire reassessment proceedings were vitiated. We, therefore, relying on the aforesaid decision in the case of Jayanthi Natarajan (supra) and Trend Electronics [2015 (9) TMI 1119 - BOMBAY HIGH COURT] hold that since the procedure required to be followed has not been followed the entire assessment proceedings are vitiated and therefore we hold the assessment order passed by the AO to be bad in law and thus set it aside. Appeals of the assessee are allowed.
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