#Section 148
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Issue of notice u/s 143(2) before finalisation of reassessment order is mandatory
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AO not empowered to initiate reassessment proceedings upon a mere change of opinion
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AO is time bound to dispose of objections in response to notice u/s 148 by a speaking order: HC
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Mere copy of notice given during reassessment proceedings will not meet mandatory requirement of issue & service of notice
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Analysis of materials after reopening of assessment is post mortem exercise which is not permitted u/s 147 : HC
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Section 147 can be invoked only if AO has reason to believe that taxable income has escaped assessment
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Sec.292BB- Service of Notice- Objection raised prior to completion of reassessment is valid
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Reassessment u/s 150(1) due to an appeal not permissible if it’s already time barred
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Entire law on whether reopening of assessment in the absence of "fresh tangible material" is permissible reviewed
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Reassement based on point considered during original assessment not permissible
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Re-opening due to mere audit objection not valid
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Reassessment u/s 147 is void if reasons for reopening not provided despite specific request of assessee
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Delivery of notice u/s 148 at correct address of assessee is foundation for initiation of reassessment proceedings – ITAT
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