Reopening of assessment: completed assessments cannot be reopened by issuing fresh reassessment notices under the substituted procedure.

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....Reopening of assessment under the reformed reassessment procedure is impermissible once an assessment order has been passed; the note explains that where prior proceedings under the old regime did not result in an assessment order, a fresh notice within the statutory limitation window may be issued in line with recent higher-court guidance, but once an assessment order exists there is no scope to issue a fresh reopening notice or reopen the assessment under the substituted procedure. The piece contrasts the pre-reform practice permitting returns after notice with the effect of the new regime and concludes finality of completed assessments.....