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2022 (11) TMI 248 - HC - Income TaxReopening of assessment u/s 147 - Eligibility of reasons to believe - HELD THAT:- We are of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus with the formation of the belief that income chargeable to tax has escaped assessment. It is equally trite that sufficiency or adequacy of reasons cannot be gone into in a proceeding under Article 226 of the Constitution of India. That apart, we are at a stage prior to issuance of notice under Section 148 of the Act. A detailed analysis is neither warranted nor justified. As rightly pointed out in Anshul Jain Vs. Principal Commissioner of Income Tax [2022 (10) TMI 3 - SC ORDER] petitioner would have ample opportunities to agitate his contentions during the reassessment proceedings. We see no ground to entertain the writ petition.
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