#Section 147
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Where person has dual capacity, notice u/s. 148 must specify particular capacity
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Number of notices that can be issued under section 148
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S. 148 Notice to every partner in the case of a firm is not necessary
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Fresh notice is not necessary when reassessment is set aside for non-observance of natural justice
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Notice u/s. 148 gives jurisdiction to AO to proceed to make reassessment
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Validity of Reassessment Notice U/s 148 ‘based on information received from Revenue Audit’
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Reassessment on ground of treatment of cenvat credit in closing stock not valid if assessee furnishes full details
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Reassessment initiated to disallow loss on hedging of metals losses is untenable if losses were allowed originally
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Reassessment to check excess disallowance of deduction not justified if primary facts were disclosed during original assessment
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Reassessment Notice u/s. 148 notice issued by a non-jurisdictional AO is not valid
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Reassessment not justified if no failure by petitioner to disclose truly & fully all material facts
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SC issues notice to Amitabh Bachchan
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Even Intimation u/s. 143(1) cannot be reopened u/s 147 without fresh material – HC
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