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2019 (3) TMI 436 - AT - Income TaxReopening of assessment - non complying with the mandatory conditions of section 147 to 151 and without recording valid reasons as per law - HELD THAT:- Assessee appeared on 12.8.2015 and stated that original return filed by the assessee may be treated the return of income filed in response to the notice u/s. 148 of the Act, but on the same date the AO given the notices to the assessee i.e. 12.8.2015 u/s. 143(2) which shows non-application of mind on the part of the of the AO. Therefore, notice under section 143(2) is invalid and resultantly, the assessment is vitiated and is liable to be quashed. Accordingly, set aside the orders of the authorities below and quash the reassessment proceedings in the matter and allow appeal of assessee.
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