#Section 148
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Unsigned reason cannot be treated as reasons recorded
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Section 148 notice without proper sanction U/s. 151(1) is invalid
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Notice U/s. 148 invalid if AO not issued notice U/s. 143(2)
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HC finds no merit in Challenge to Reassessment Notice issued to Robert Vadra’s Firm
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Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion; AO can examine genuineness of share premium U/s 68
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Sec 292B can’t be cure Non-application of mind in issue of Re-Assessment Notice
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No reassessment merely for non reflection of ITR filed manually in IT system
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Sanction for issuing a reopening notice cannot be mechanical
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Penalty cannot be imposed for Bonafide omission during return filing, surfaced during Section 148/148 Assessment
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Directions of JCIT or CIT cannot only be reason to believe for reopening of assessment
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When the very basis of the reopening of the assessment having been eroded, notice under section 148 quashed in the case of Oracle
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AO cannot Review his Own Order by invoking Sec 147 of Income Tax Act
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To invoke sec. 147 AO has to prove that Assessee Escaped Income
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