Validity of the reopening of proceedings under section 147 -...

Validity of the reopening of proceedings under section 147 - Assessee contended that, assessment was framed on the basis of mere internal office note, without recording reasons as envisaged u/s 148 of the Act and according to the assessee there is no nexus between the alleged reasons and the assessment framed - non adherence to the principles of natural justice - the reasons supplied to the assessee are not the same and verbatim. - AT