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Court Upholds Reopening of Assessment; Commissioner's Satisfaction Valid u/ss 147 and 151.
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....Reopening of assessment u/s 147 - Scope of conditions as envisaged as per provisions of Section 151 - in the present case, the conditions U/s 151 of the Act for recording satisfaction by the Commissioner has been validly done as the said satisfaction was on the basis of reasons recorded by the A.O. and not de hors it and thus according to us, the satisfaction independent of reason recorded by the A.O. is not envisaged any way in Section 151 of the Act. - AT....