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2016 (5) TMI 1267
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....ani For the Respondent : Mr. Nirmal C. Mohanty ORDER P. C. 1. Heard. Rule. 2. Both these petitions under Article 226 of the Constitution of India challenge Notices dated 31st March, 2015 seeking to reopen assessments for Assessment Years 2010-11 and 2011-12. The reasons recorded by the Assessing Officer in support of both the impugned notices are identical save and except the quantu....
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....h January, 2013 for Assessment Year 201011 and 12th March, 2014 for Assessment Year 201112. On the date when the Assessing Officer passed the orders under Section 143(3) of the Act, the decision of the Apex Court in Catholic Syrian Bank Ltd. (supra) was very much available. Thus, prima facie, the Assessing Officer would have formed a necessary opinion taking a view that the decision of the Apex Co....