Reopening record verification and sanction endorsement questions led to adjournment for further record checking.

The dispute concerned whether the reopening record matched the reasons supplied to the assessee and whether the original file contained the sanctioning endorsement relied on by the Revenue. The court found that further verification of the record was necessary before the matter could be dealt with conclusively, and the matter was adjourned for that purpose.

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Issues: Whether the reopening record and the reasons supplied to the assessee were consistent, and whether the original file contained the sanctioning endorsement relied upon by the Revenue.

Outcome: The matter was adjourned to enable further verification of the record.

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