Reassessment couldn’t be initiated on fact which was subject matter of consideration while passing assessment order

INCOME TAX: Where Assessing Officer sought to reopen assessment in case of assessee on ground that assessee had wrongly claimed deduction under section 80-IB(10) as completion certificate for project was not obtained on or before stipulated date, however, said fact was a subject matter of consideration by Assessing Officer while passing Assessment Order and no new reasons had been recorded prior to issuance of impugned notice, reopening of assessment on bald assertion that assessee had failed to

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