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2014 (1) TMI 448
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.... Mr. P.R. Mullick, Adv JUDGEMENT PER : Barin Ghosh, CJ The completed assessment was purported to be opened in exercise of power under Section 147 of the Income Tax Act in view of a subsequent pronouncement by a Court. In McDermott International Inc Vs. Additional Commissioner of Income Tax and others reported in 259 ITR 138, a Division Bench of this Court has held that the judgment of a higher....