Reassessment Invalid if AO Assumed Jurisdiction in Original Order under Sec 143(3) & 147; No Sec 148 Notice Permitted.

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....Validity of reopening of assessment - Once the AO rightly or wrongly assumed jurisdiction in framing the assessment order u/s 143(3) r.w.s. 147 of the Act, in view of the fact that once the assessment order is subject matter of the further appeal, reassessment cannot be framed on the same issue on issuing notice u/s 148 as the original assessment gets merged with the order of the Higher Appellate Authority. - AT....