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2020 (3) TMI 884 - PUNJAB AND HARYANA HIGH COURTReopening of assessment u/s 147 - HELD THAT:- We find that the order of the Tribunal is correct. The mere fact that reasons exist on the file cannot sanctify them and the only way to ascertain whether the requirements under Section 147 of the Act have been met out would be at the very least that the assessing officer sign the same. Without signatures, the document becomes anonymous piece of paper to which no credence can be given. The action under Section 147 of the Act is quasi-judicial action and if it is permitted that such action can be done as anonymously, it would have very serious consequences in other cases also. If the Court accepts such pieces of paper who can tomorrow stop an assessee from substituting a signed paper with another unsigned paper? Moreover the reasons are undated, hence do not establish that they were recorded prior to issuance of notice. Appeal is dismissed.
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