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Reassessment Notice U/s. 148 void even if issued by authorities who rank higher than competent authority

Case Law Details

Case Name
CIT Vs Soyuz Industrial Resources Ltd. (Delhi High Court)
Date of Judgement/Order
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Advertisement Brief Facts of the Case and Question of Law Brief Facts The brief facts of the case are that for Assessment Year (AY) 2002-03, the assessee had filed its returns in a normal course on 16.10.2002. The assessment was framed under Section 143(1). Based upon information received by the Assessing Officer (AO), a satisfaction note was recorded sometime in early 2009 and a notice was issued in 2009 i.e. four years beyond the end of the assessment year, under proviso to Section 147(1). The re-assessment proceedings were completed on 31.12.2009. The assessee in its appeal urged that...
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