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    <title>2019 (12) TMI 1498 - ITAT DELHI</title>
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    <description>Reassessment under sections 147 and 148 was invalid because the recorded reasons for reopening were not supplied to the assessee, were not produced before the appellate forums, and were not otherwise on record. The validity of notice under section 148 had to rest on reasons existing before the notice was issued, and later developments could not cure the defect. The record also showed pre-notice inquiries despite no pending proceedings and without authority under section 133, so the assumption of jurisdiction was unsupported and unauthorized. The assessment made pursuant to the reopening was annulled.</description>
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    <pubDate>Fri, 20 Dec 2019 00:00:00 +0530</pubDate>
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      <title>2019 (12) TMI 1498 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=295346</link>
      <description>Reassessment under sections 147 and 148 was invalid because the recorded reasons for reopening were not supplied to the assessee, were not produced before the appellate forums, and were not otherwise on record. The validity of notice under section 148 had to rest on reasons existing before the notice was issued, and later developments could not cure the defect. The record also showed pre-notice inquiries despite no pending proceedings and without authority under section 133, so the assumption of jurisdiction was unsupported and unauthorized. The assessment made pursuant to the reopening was annulled.</description>
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      <pubDate>Fri, 20 Dec 2019 00:00:00 +0530</pubDate>
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