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Reassessment u/s 148 Invalid: AO's Original Opinion on Bad Debts from Export Receivables Stands Valid.

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....Reassessment u/s 148 - AO in original assessment has formed an opinion that the bad debts from export receivables can be written off during the pendency of the application for approval from RBI - notice u/s 148 is without jurisdiction and authority of law as reopening merely on the ground that from the material once a view earlier adopted was erroneous one, such facts cannot be a ground for reassessment....

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