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2014 (4) TMI 239 - HC - Income TaxNotice for reopening of assessment u/s 147 of the Act – recording of satisfaction before issuing notice u/s 148 - Held that:- the conditions are sine qua non - the conditions must reflect in the notice itself - In the absence of the same, exercise of jurisdiction in issuance of the notice under aforesaid provision is patently illegal -Nothing has been disclosed or shown even in the subsequent stages – thus, there is no option left, but to set aside the first notice dated March 30, 2012, and the consequential steps being order dated January 15, 2013 – Decided in favour of Assessee.
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