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2022 (3) TMI 20 - AT - Income TaxReopening of assessment u/s 147 - validity of reasons to believe - HELD THAT:- We find that the reasons for reopening are same for the A.Y. 2008-09, A.Y. 2009-10 and A.Y. 2010-11. No doubt, each Assessment Year is to be seen differently, but the note from the Investigation unit indicate the same pattern of expenditure claimed over a period of 5 years. Two of these years were dealt with by the Hon'ble High Court and hence the same ratio applies to the year before us also. The SLP filed by the revenue has been summarily dismissed by the Hon'ble Apex Court. Hence, keeping in view the judgments of the Hon'ble Delhi High Court in the case of the assessee for the A.Y. 2009-10 & A.Y. 2010-11 and order of the Hon'ble Apex Court, we decline to interfere with the order of the ld. CIT(A) quashing the notice issued u/s. 148 in the case of the assessee. - Decided against revenue.
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