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1977 (4) TMI 57 - ITAT DELHI-BExtract: ....... original assessment proceedings. In the circumstances we hold that the question of application of s. 147(a) of the Act will not apply. In the result, the Appellate Assistant commissioner was justified in coming to the conclusion that the notice issued under s. 148 in this case was bad in law. 6. In the result, the Departmental appeal is dismissed.
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