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2015 (3) TMI 1339 - ITAT MUMBAIReopening of assessment - non supplying of reasons to believe to assessee - Held that:- We find that this letter is nothing but a questionnaire served upon the assessee. By any stretch of imagination, a questionnaire cannot replace or supplement the supply of reasons to the assessee which in the light of the judicial decisions discussed hereinabove is sine-qua- non for reassessment - DR could not adduce any evidence which could suggest that the reasons were actually supplied to the assessee. Considering the facts of the case in the light of the judicial decisions referred to hereinabove, we set aside the assessment order for want of jurisdiction and quash the reassessment order for both the years under consideration. - decided in favour of assessee,
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