#Section 148
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Reopening in absence of fresh tangible material to form an opinion is invalid
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Reopening notice based on satisfaction of some other authority is invalid
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Section 148 notice without Approval of Competent Authority is invalid
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Reopening invalid if reasons for same not speaks of escapement of income
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Litmus Test For Issue of A Valid Notice Under Section 148
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S. 147 AO cannot proceed mechanically & on erroneous information supplied to him by investigation wing
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Recording of reasons to believe & not reasons to suspect is pre-condition of section 147
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Assessee cannot be blamed for non-disclosure if AO had such info during assessment proceeding
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AO cannot do reassessment after assessment by Settlement Commission
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S.147 Basic condition of ‘reason to believe’ applies even to s.143(1) intimations
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Reassessment for Change of opinion not objected during Assessment- HC dismisses writ petition
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Revisionary power U/s. 263 cannot be exercised on ground not covered in Re-Opening
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Reassessment by sending section 148 notice to old address of assessee is invalid
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