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2020 (1) TMI 733 - HC - Income TaxReopening of assessment u/s 147 - reasons to believe - HELD THAT:- As perused the reasons in this case and the objections filed by the Petitioner giving explanation and creditworthiness of the Petitioner. The order passed by the Respondent No.1 – Assessing Officer disposing of the objections, do not show application of mind qua the objections raised by the Petitioner. Firstly there is a reference to fact that there was no scrutiny assessment, then the objection of the Petitioner on law regarding jurisdiction is commented on then it is stated that earlier no documents could be examined because it is the case of intimation u/s 143(1) AO reproduced the paragraphs regarding what is meant by “reasons to believe” and passed the order. In view of the fact that there is absolutely no application of mind whatsoever while disposing of the objections to the factual errors and factual aspects pointed out by the Petitioner, we find that arguable case is made out. - The earlier ad-interim order to continue
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