#Section 147
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5,090 articlesIncome Tax
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L&T Case: Classic example of change of opinion
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AO not justified in reopening based on mere report of investigation wing without independent application of mind
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Reopening invalid if Officer issuing notice different from officer recording reasons
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Reassessment invalid if section 148 notice not served within stipulated period
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Section 148 Notice issued in the name of dead person was invaild
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Notice u/s 148 cannot be issued for mere insufficient compliance to Letters
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Proceedings u/s 148 could not be initiated for verification of sources of investment
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Section 148 Notice issued for verification of information was not valid
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Notice u/s 148 invalid if issued but not served properly to proper person
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Tax administration not expected to collect taxes based on ignorances of assessee
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Section 148 Notice based on Investigation report sustainable if AO enquired before issuing such Notice
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Reassessment not valid if Reason for issuing reassessment notice not furnished to assessee
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Section 148 notice in name of deceased assessee is invalid
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