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2022 (6) TMI 657 - HC - Income TaxReopening of assessment u/s 147 - violation of principle of natural justice - HELD THAT:- As interfere with the impugned assessment order for the reason that it is an appealable order and further that there is no procedural illegality or infirmity during the impugned reassessment proceeding and in passing the impugned assessment order. The principles of law and guidelines as laid down in the case of GKN Driveshafts (India) Ltd. 2002 (11) TMI 7 - SUPREME COURT has also been fully observed and there is no violation of principle of natural justice in this case since against the impugned notice under Section 148(b) of the Act, recorded reason was furnished to the petitioner. Opportunity to file objection to the same was given. Even draft assessment was served and opportunity to make objection against the same was also furnished to the petitioner. Thereafter the impugned final assessment order has been passed. This Court in exercise of its constitutional writ jurisdiction under Article 226 of the Constitution can consider the decision making process but not the decision itself.
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