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Section 148 cannot be used to review decisions made u/s 143(3); use Section 263 for errors.
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....Validity of reopening u/s 147/148 - provisions of Section 148 cannot be used for reviewing the decision taken by the AO u/s 143(3) - There is a demarcation and separation of jurisdiction even for revision for an order suffering from error and therefore the remedy for such erroneous order is provided u/s 263 - AT....