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1982 (1) TMI 39 - HC - Income TaxExtract: .......bunal, in our opinion, was not justified in its view that the ITO had jurisdiction to reopen the assessment under the provisions of cl. (a) of s. 147 of the Act. Our answer to the question referred to us is, therefore, in the negative and against the department. In the circumstances of the case, parties shall bear their own costs of this reference.
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