Assessee's Late Request for Reasons u/s 147 Notice; Provided by Assessing Officer in 35 Days Post-Appeal.

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....Reopening of assessment u/s 147 - non-supply of reasons recorded for issuance of notice u/s 148 - In the instant case, it is an admitted position that the assessee for the first time applied for the copy of the reasons after passing of appellate order by ld. CIT(A) and the same was provided by the AO in 35 days and therefore, it is crystal clear on facts that the assessee never asked for the copy of the reasons during the entire assessment and appellate proceedings, and therefore, there was no obligation as well as occasion for the AO to supply copy of the reasons to the assessee. - AT....