Assessee Challenges Reopening of Proceedings Under Sec 147; Claims Lack of Proper Reasoning and Violation of Natural Justice Principles.

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....Validity of the reopening of proceedings under section 147 - Assessee contended that, assessment was framed on the basis of mere internal office note, without recording reasons as envisaged u/s 148 of the Act and according to the assessee there is no nexus between the alleged reasons and the assessment framed - non adherence to the principles of natural justice - the reasons supplied to the assessee are not the same and verbatim. - AT....