#Section 147
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Furnish compilation of judgments on reassessment to ACIT: HC direct Counsel
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Notice U/s. 148 served at factory premises of Assessee on security guard is valid
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If section 147 proceedings initiated after Income deceleration by Assessee than conclusion of non- voluntary return is untenable
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Reopening cannot be done for Mistake committed by AO in Original Assessment
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No Penalty for non compliance of section 148 notice
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Proper Notice U/s. 148 is must for initiating reassessment proceeding
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Validity of Notice U/s 148 after 4 years from the end of relevant A.Y. without specifying the amount of income escaping assessment
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Reopening based on vague and non-speaking reasons is reopening without jurisdiction
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Reopening for non-disclosure of S. 14A disallowance calculation method is invalid
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Approval for reopening by observing merely ‘जी हाँ मैं संतुष्ट हूँ’ is not legally tenable
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Even Sec.143(1) assessment cannot be reopened without proper reason to believe
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Failure to provide document relied for reassessment makes reopening void
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Reassessment Proceeding initiated after 6 years is not valid; Department must prove dispatch of notice
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