#Section 147
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Reopening based on facts disclosed in Profit & Loss account during Original Assessment not permissible
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After expiry of 4 Years no notice u/s. 148 can be issued without approval of CCIT or CIT
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Reopening of assessment beyond 4 years not permitted without finding assessee’s failure to produce material facts
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Revenue Must have Tangible Material to initiate income escaping Assessment
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Completion of reassessment without issue of reasons is invalid: HC
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Reopening of assessment not permissible where charges on Assessee are not specific: HC
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Reopening to rectify Mistake committed during Original Assessment not permissible
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Re-opening of assessment not permissible on same set of materials considered in original assessment
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Issue of notice u/s 143(2) before finalisation of reassessment order is mandatory
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AO not empowered to initiate reassessment proceedings upon a mere change of opinion
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AO is time bound to dispose of objections in response to notice u/s 148 by a speaking order: HC
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Mere copy of notice given during reassessment proceedings will not meet mandatory requirement of issue & service of notice
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Analysis of materials after reopening of assessment is post mortem exercise which is not permitted u/s 147 : HC
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