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Reopening of assessment u/s 147 - AO gets jurisdiction to reopen the assessment only after he records the reasons for reopening and thereafter, issues notice u/s 148 within the prescribed time and only on fulfilment of the conditions prescribed therein. None of these conditions have been fulfilled by the AO. No hesitation in holding that the re-assessment proceedings were not initiated validly and therefore, the re-assessment order is set aside. - AT
Reopening of assessment u/s 147 - AO gets jurisdiction to reopen the assessment only after he records the reasons for reopening and thereafter, issues notice u/s 148 within the prescribed time and only on fulfilment of the conditions prescribed therein. None of these conditions have been fulfilled by the AO. No hesitation in holding that the re-assessment proceedings were not initiated validly and therefore, the re-assessment order is set aside. - AT
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