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1992 (4) TMI 80 - ITAT DELHI-C
Extract:
.......d enough for action under section 147(a)/ 148, without there being any fresh material on record to justify a departure, from the past. In the final analysis, we cancel the reassessment orders for both the assessment years under appeal being of the view that proceedings under section 147(a)/148 were not validly initiated. 15. The appeals are allowed