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2022 (4) TMI 1021 - HC - Income TaxValidity of Reopening of assessment u/s 147 - proof of fresh tangible materials available at the hands of the assessing officer to reopen the assessment under section 147 - HELD THAT:- The assessment for the year 2014-15 in respect of the appellant firm was completed under section 143(3) on 07.10.2016. Subsequently, the respondent reopened the assessment under section 147 by issuing notice under section 148 of the Act, to which, the appellant filed its objections on 12.07.2021. Thereafter, as per the order of this court in [2021 (8) TMI 1294 - MADRAS HIGH COURT] at the instance of the appellant, the respondent passed the order rejecting the said objections, on the premise that there are fresh tangible materials available at the hands of the assessing officer to reopen the assessment under section 147 - The said order was put to challenge before the learned Judge[2022 (1) TMI 1230 - MADRAS HIGH COURT]which was dismissed, by the order dated 10.01.2022 impugned herein. We find no reason to interfere with the order of the learned Judge [2022 (1) TMI 1230 - MADRAS HIGH COURT] even prior to the passing of final order in the re-assessment proceedings. Judge has pointed out in the order impugned herein that the respondent has only indicated the reasons and justifications for reopening the assessment and has not come to a definite conclusion as to whether any case has been made out for re-computing the income of the appellant. Judge has granted liberty to the appellant to file reply/representation as to why the completed assessment proceedings deserves to be confirmed. Such a conclusion arrived at by the learned Judge, in our opinion, does not require any interference.
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