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    <title>Notice issued without sufficient reasons to initiate reassessment is not sustainable</title>
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    <description>The assessing authority issued a reassessment notice alleging sales to a shell entity, but the reasons recorded were vague and lacked material showing the purchaser was a sham. The authority had not independently applied its mind or conducted inquiry, and reopening must be judged on the reasons recorded which cannot be supplemented by affidavits or oral submissions. Accordingly, the statutory preconditions for initiating reassessment were not satisfied.</description>
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      <description>The assessing authority issued a reassessment notice alleging sales to a shell entity, but the reasons recorded were vague and lacked material showing the purchaser was a sham. The authority had not independently applied its mind or conducted inquiry, and reopening must be judged on the reasons recorded which cannot be supplemented by affidavits or oral submissions. Accordingly, the statutory preconditions for initiating reassessment were not satisfied.</description>
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