Reopening of Tax Assessment Invalid Due to Late Notice Issuance and Improper Directions u/ss 147, 150, and 149(1)(b).

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....Reopening of assessment u/s 147 - Validity of Direction of CIT(A) u/s 150 - as per provisions of section 149(1)(b), notice u/s 148 could have issued by the end of assessment year 2018-19 which had already elapsed when the direction was issued - since direction of CIT(Appeals) is not in accordance with law reopening was also not valid....