Assessee's Document Failure in Section 147 Reassessment Doesn't Prove Notices Were Not Issued u/ss 143(2), 142(1).

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....Reassessment u/s 147 - in these facts that the assessee could not have placed on record the required documents within any notice at all before section 133(6)/131 process - Mere on non production of the notice(s) in question; in our considered view, is not sufficient to conclude that the AO had not issued sec. 143(2) and sec. 142(1) - AT....