Reopening a closed assessment is a serious business and therefore ought to meet all the tests of reopening. The Supreme Court in [2024] 460 ITR 729 (SC) in dismissing the department SLP held as invalid the action for reopening which was based solely on an audit objection without satisfying the test of independent application of mind of the AO. This mind application test is today even more relevant in the present protocol for reopening which revolves around enquired piece of information from select source/database. AO who merely relies on gathered information in his 148A (b) notice without anything more would defy the scheme/law and this SC ruling.
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