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Reopening of Assessment u/s 148 Deemed Illegal Due to Lack of Material Facts by Assessing Officer.

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Full Text of the Document

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....Reopening u/s 148 - accommodation entry - recording of reasons to belief - AO did not mention any material facts in the reasons such as original assessment u/s 143(3), failure on the part of the assessee to disclose fully and truly all material facts - assumption of jurisdiction u/s 147/148 is clearly illegal and bad in Law....