Assessment Reopening Invalid: Show Cause Notice Lacks Basis u/s 147, Making Section 148 Notice and Assessment Void.

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....Reopening of assessment on the basis of show cause notice issued by the Excise Authorities - once the very foundation on which the action u/s 147 had been initiated had cease to exist; both logically and legally what emerges is that notice u/s 148 of the Act was invalid and the assessment framed u/s 147/143(3) was also vitiated.....