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    <description>A reassessment notice under Section 148 was found unsustainable because it did not disclose the reasons forming the basis of the reopening. The court treated the absence of recorded satisfaction as a substantive defect, since an assessee must know the grounds of reopening to respond effectively and receive a fair opportunity of defence. The notice was therefore quashed as non-speaking, and the matter was remanded for fresh consideration through a speaking order.</description>
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      <description>A reassessment notice under Section 148 was found unsustainable because it did not disclose the reasons forming the basis of the reopening. The court treated the absence of recorded satisfaction as a substantive defect, since an assessee must know the grounds of reopening to respond effectively and receive a fair opportunity of defence. The notice was therefore quashed as non-speaking, and the matter was remanded for fresh consideration through a speaking order.</description>
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