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Reopening of assessment u/s 147 - date of the issuance of the Notices - In the present case, the Notices...

Reopening of assessment u/s 147 - date of the issuance of the Notices - In the present case, the Notices were sent from the designated e-mail ID of the respective JAOs, fulfilling all requirements of authentication as per the relevant provisions. There was no doubt in the mind of the assessees that the Notices were sent by the Department. Therefore, the Notices falling under category ‘B’ would not be invalid simply because DSCs were not appended to the Notices. - HC .....

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