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C.I.T New Delhi vs Orient Craft Ltd. on 20 January, 2014

"16. In so far contentions of the department that the Assessing Officer did not get opportunity to apply his mind on the documents 19 ITA No.608/PUN/2014 ITA No.623/PUN/2014 CO Nos.20 & 28/PUN/2015 furnished by assessee as the original assessment was completed u/s.143(1), we do not find any force in the said contentions. The Hon‟ble Delhi High Court in the case of CIT Vs. Orient Craft Ltd. (supra) has held that expression, „reason to believe‟ does not have different meaning, where assessments are framed u/s.143(1) and where assessment is completed u/s.143(3) of the Act. The relevant extract of the findings of the Hon‟ble High court are as under :
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