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Validity of the reopening of assessment - validity of the notice u/s 148 - wrong understanding of the legal position - The assessee, in the case on hand, chose the second option, which, in law, was permissible to be done by the assessee. Therefore, both the CIT(A) as well as the Tribunal fell in error in holding that the assessee was estopped from challenging the validity of the notice u/s 148 - HC
Validity of the reopening of assessment - validity of the notice u/s 148 - wrong understanding of the legal position - The assessee, in the case on hand, chose the second option, which, in law, was permissible to be done by the assessee. Therefore, both the CIT(A) as well as the Tribunal fell in error in holding that the assessee was estopped from challenging the validity of the notice u/s 148 - HC
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