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2021 (8) TMI 725 - HC - Income TaxReopening of assessment u/s 147 - Reason to believe - HELD THAT:- In the present case, admittedly, the reopening is made within a period of four years. Thus, the reasons furnished for reopening, if satisfied, would be sufficient for continuance of reassessment proceedings and for its conclusion. Perusal of the reasons furnished as well as the objections raised and the disposal of such objections, as discussed would reveal that the petitioner has not substantiated the grounds raised for the purpose of setting aside the impugned order and therefore, this Court has no hesitation in arriving a conclusion that the reopening of assessment is made in consonance with the provisions of 147 of the Act and there is no infirmity or perversity as such. As far as the judgments relied on by the petitioners are concerned, the principles laid down by the Apex Court in RAYMOND WOOLLEN MILLS LIMITED VERSUS INCOME-TAX OFFICER AND OTHERS [1997 (12) TMI 12 - SUPREME COURT] are not in dispute. Application of principles with reference to the facts and circumstances of the case are of paramount importance. Even the respondents have not seriously disputed on the principles relied upon, but perusal of the reasons furnished, objections raised and the disposal of objections by the authority competent are sufficient enough to meet out the mandatory requirements as contemplated under Section 147 of the Act and thus, the reassessment proceedings are to be allowed and the said proceedings are to be concluded as expeditiously as possible. WP dismissed.
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