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2004 (7) TMI 328 - ITAT LUCKNOW
Extract:
....... the assumption of jurisdiction under section 147 of the Act was invalid. We, therefore, hold that the initiation of proceedings under section 147 of the Act as well as the additions made in the re-assessment order are invalid. The re-assessment order is, therefore, cancelled. 22. In the result, all the appeals directed by the assessee are allowed.