Notice Validity u/s 148-A Hinges on Clear Seven-Day Notice and Prima Facie Opinion on Escaped Income.

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....Reopening of assessment - validity of notice issued u/s 148-A - seven days clear notice issued or not? - the authority is only required to form a prima facie opinion of any income having escaped assessment and thereafter proceed under Section 148 of the Income Tax Act. The concept of “free play in the joints” should be made available to the authority which is empowered to take a decision under Section 148-A of Income Tax Act. The decision under Section 148-A of the Income Tax perse does not fasten any kind of liability or penalty upon the assessee. - HC....