#Section 147
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HC quashed reassessment notice u/s 148 against Infosys Ltd.
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Reassessment without notice u/s 143(2) was bad in law & cannot be revised u/s 263
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Reassessment without issuance of mandatory notice u/s 143(2) was invalid
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Reassessment after 4 years where assessee made true and full disclosure in original assessment was not valid
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Revisionary jurisdiction cannot be exercised against Void order
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Reopening in absence of fresh tangible material to form an opinion is invalid
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Reopening notice based on satisfaction of some other authority is invalid
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Section 148 notice without Approval of Competent Authority is invalid
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Reopening invalid if reasons for same not speaks of escapement of income
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S. 147 AO cannot proceed mechanically & on erroneous information supplied to him by investigation wing
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Recording of reasons to believe & not reasons to suspect is pre-condition of section 147
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Assessee cannot be blamed for non-disclosure if AO had such info during assessment proceeding
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AO cannot do reassessment after assessment by Settlement Commission
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