1980 (2) TMI 21

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....llowing question in his petition : " Whether, on the facts and in the circumstances of the case, the reopening of the assessment under section 147(a) was legal and valid ? " The aforesaid question was decided against the assessee in an earlier proceeding under art. 226 of the Constitution. The Tribunal has dismissed the appeal filed by the assessee by following the said judgment of this court a....