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Court Quashes Reassessment Notice for Lack of Jurisdiction u/s 147 of the Income Tax Act.
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....Reopening of assessment u/s 147 - non taking of certain objections in response to the notice - If there is legal contention which goes to the root of the matter and which would render the action of the AO of issuing notice of reassessment without jurisdiction, such a ground cannot be showed out merely because in the written objections, the petitioner had not thought of raising it - notice quashed.....