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2022 (3) TMI 729 - HC - Income TaxReopening of assessment u/s 147 - HELD THAT:- Respondent No.1 has initiated re-assessment proceedings passed only on audit objection raised by the Revenue and to which the then AO i.e., ACIT Bangalore had replied and states in its letter dated 30th March, 2011 and there is no error in the original assessment completed by him and that audit objection is not accepted by him. Therefore, if the AO after application of mind to the facts of the case passes the original assessment order and comes to a certain conclusion and thereafter even does not accept audit objection raised by the audit party on the said conclusion, re-opening by the subsequent Assessing Officer only on the basis of such audit objection is bad in law. This has been raised in ground “F” to the petition and in the affidavit in reply of one Mr. P.D. Chougule affirmed on 25th June, 2015, respondent admit that the contents thereof are true and correct.
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