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M/s Krishna Developers And Co. Versus Dy. Commissioner of Income Tax

2018 (2) TMI 607 - SUPREME COURT

Validity of reopening - Validity of notice u/s 148 when scrutiny assessment was made but same was annulled - doctrine of merger - Held that:- SLP dismissed. HC order confirmed [2017 (8) TMI 241 - GUJARAT HIGH COURT] - HC has held that the reopeni .....

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entertained only part of the assessee's appeal, the principle of merger as flowing from the proviso to section 147 of the Act would not apply. - Assessing Officer proceeded to pass the order of assessment discarding the assessee's objection of n .....

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law. There is thus no original assessment. There is no opinion of the Assessing Officer on record. There is no question of the assessee's return having been scrutinised. There is therefore, no change of opinion.- Decided against assessee. - Special .....

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