Assessment Reopening u/s 147 Challenged Due to Delayed Notice and Discrepancies in Department's SPA Number Records.

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....Reopening of assessment u/s 147 - Delay in issuing notice - The speed post booking list maintained by the Department is of no use in this matter because there is discrepancy with respect to the SPA number and also the SPA numbers that followed this particular entry are not in the immediate proximity of this particular ED48...... and also that they are corrected SPA numbers with 9 numericals. - AT....