Unauthorized Section 147 Order Invalidates Section 148 Notice; Assessments Cannot Reopen Without Meeting Preconditions.

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....Reopening of assessment u/s 147 - Once an order u/s 147 is found to be without authority, the consequential notice under Section 148 of the Act has no legs to stand on and the matter or the assessment cannot be reopened in the absence of the statutory pre-condition being met. - HC....