#Section 147
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Re-opening being exceptional power, revenue to comply pre-requisite condition of ‘reasons’ strictly
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Reopening u/s 147 based on mere office note of predecessor AO not permissible
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Assessment U/s. 147 not valid when time for scrutiny assessment U/s. 143(3) not lapsed
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Reopening by simply treating loan entry as income which has escaped from assessment is not appropriate
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Tangible material required to reopen assessment u/s 148 of Income Tax Act,1961
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In Reopening AO cannot pass Composite Order for Assessment and for rejection of objection
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Reassessment without application of mind and examining the facts is invalid and liable to quash
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Intimation u/s 143(1) is not an assessment, AO authorized to make reassessment u/s 147 subsequently: SC
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Re-opening u/s 148 based on of revisiting of existing material is bad in law
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Reassessment proceeding based on ED information without correlating with returns filed is invalid
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Notice U/s. 148 issued to legal representative of deceased assessee is legal & valid
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Reopening of Assessment merely on the basis of change in opinion is invalid
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Without any supporting material A.O. cannot substitute market value
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