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of Validity of reopening of assessment u/s 147 - Search of another person - There has been no action on assessee under section 132 or requisition is made under section 132A as per section 153C(2). - Reopening notice is issued as assessee failed to include the disclosure made as per statement recorded in the return filed for year under consideration. It is apparently clear that the reopening notice has been issued subsequent to the filing of return for year under consideration by assessee - AT
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