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2020 (6) TMI 314 - ITAT MUMBAIReassessment proceedings u/s. 147 - proceeding initiated on the basis of an audit objection - HELD THAT:- We have found cogent reasons for not appreciating such reopening as an abundant caution by the Revenue only on the basis of an internal audit objection particularly when the same officer himself has objected such reopening on merit; consideration whereof has already been done by him in the original proceeding. As enlightened by the ratio laid down by SHUBHLAXMI PETROHEMICALS [2016 (9) TMI 1571 - ITAT AHMEDABAD] in the same set of facts and relying upon the same we find no justification for approving the reassessment proceeding initiated by the Revenue. Hence, the same is found to be devoid of any merit and thus quashed. - Decided in favour of assessee. Order being pronounced after ninety (90) days of hearing - COVID-19 pandemic and lockdown - HELD THAT:- Taking note of the extraordinary situation in the light of the COVID-19 pandemic and lockdown, the period of lockdown days need to be excluded. See case of DCIT vs. JSW Limited [2020 (5) TMI 359 - ITAT MUMBAI].
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