#Section 148
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Reopening of assessment without any new information is unjustified
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Notice issued without sufficient reasons to initiate reassessment is not sustainable
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Reopening of assessment despite full & true disclosure of material facts is unjustifed
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Mere ‘reason to believe’ not satisfy condition for reopening of assessment
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Reopening of assessment and imposition of penalty set aside as AO failed to satisfy HC direction
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If foundational allegation found to be false/non-existing, entire subsequent proceedings would collapse
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Information vs. Information suggesting escapement of income from tax
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Non-supply of material referred to in reasons to believe renders reassessment proceedings bad
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Mere change of opinion cannot be a ground for reopening of assessment
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Recorded reasons for reopening can neither be improved nor substituted by an affidavit
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Reassessment proceedings becomes null & void if no valid service of section 148 notice
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Rajasthan HC stays Time barred Re-assessment Proceedings
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Reasons to Believe is foundation stone of reassessment proceedings u/s 147/148
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