#Section 148
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Reopening of assessment for non-existent and factually incorrect reasons was invalid
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Reassessment Proceeding completion without section 143(2) notice is invalid
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Section 147 Assessment invalid if reasons recorded for reopening not furnished
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Reassessment without disposing of assessee’s objections by separate order makes jurisdiction of AO ultra-vires in law
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Notice U/s. 143(2) invalid if issued without application of mind
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Reopening of assessment- Section 147 of Income Tax Act, 1961
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L&T Case: Classic example of change of opinion
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AO not justified in reopening based on mere report of investigation wing without independent application of mind
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Reopening invalid if Officer issuing notice different from officer recording reasons
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Reassessment invalid if section 148 notice not served within stipulated period
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Section 148 Notice issued in the name of dead person was invaild
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Notice u/s 148 cannot be issued for mere insufficient compliance to Letters
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Proceedings u/s 148 could not be initiated for verification of sources of investment
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Income Tax
