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2021 (9) TMI 352 - AT - Income TaxValidity of Reopening of assessment - whether no justifiable reason for the AO to reopen the assessment in this case? - HELD THAT:- Since, the Department has miserably failed to show that there were any cogent and convincing reasons for the Assessing Officer to form belief that the income of the assessee has escaped the assessment or that there was any escapement of income because of the failure on the part of the assessee to disclose fully and truly all material facts. Since no document showing the compliance of the above mandatorily requirements for reopening of the assessment u/s 147 r.w.r 148 of the Act has been produced on the file, therefore, we hold that the reopening of the assessment, in this case, is bad in law. Accordingly, the impugned assessment order passed u/s 147 of the Act is hereby quashed. - Decided in favour of assessee.
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