2019 (7) TMI 307

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..... (PER : HONOURABLE MS.JUSTICE HARSHA DEVANI) 1. Mr. Tushar Hemani, learned advocate with Ms. Vaibhavi Parikh, learned advocate for the petitioner, has invited the attention of the court to the reasons recorded for reopening the assessment under section 147 of the Income Tax Act, 1961 to submit that merely because on the basis of search conducted in the case of Shri Shailesh Shah and Shri Jignesh .....

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..... ssing Officer seeks to do is to first reopen the assessment and thereafter, try to find out the connection between the petitioner and Shri Shailesh Shah and Shri Jignesh Shah. It was submitted that it is not permissible to reopen the assessment for carrying out a roving and / or fishing inquiry, without any specific finding of escapement of income. 3. It was submitted that the reopening is also .....

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