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2012 (5) TMI 44 - DELHI HIGH COURTRe-assessment proceedings - return of income declaring loss – assessee contested against the re- assessment proceedings as notice u/s 148 has been issued beyond the period of 4 years from the end of the assessment year – Held that:- Sanction for the proposal to reopen the assessment was accorded by the ACIT on 9.3.2011, notice to reopen the assessment was issued on 15.3.2011 and reasons for reopening the assessment had been recorded on 9.3.2011. These were however supplied to the petitioner only on 30.8.2011 - There is no requirement in Section 147 or Section 148 or Section 149 that the reasons recorded should also accompany the notice issued under Section 148 and served on the assessee before the period of limitation - only a delay of 4 ½ months in supplying the reasons recorded by the AO to the petitioner cannot invalidate the reassessment proceedings - against assessee.
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