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High Court Rules: Reopening Assessment Needs Substantive Grounds, Not Just Procedural Omissions, u/s 148.

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....Validity of notice u/s 148 - The mere fact that the Assessing Officer did not give reasons for not disturbing the claim made by the Assessee in the final order of assessment would not authorize the Assessing Officer to reopen the same issue even within a period of four years - HC....