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2018 (2) TMI 165 - ITAT CUTTACKReopening of assessment - reasons to believe - Held that:- We are of the opinion that the order u/s.143(3) dated 23.12.2011 and order u/s.143(3)/147 dated 28.8.2014 are two separate appellate orders and the submission of A.R. that the order u/s.143(3) merged with u/s.143(3)/147 cannot be accepted. In the present appeal, the assessee has not raised grounds based on the order u/s.143(3)/147 of the Act and further not challenged the additions in the order u/s.143(3)/147, and we are of the opinion that appeal is not maintainable accordingly, we dismiss the appeal filed by the assessee.
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