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In favour of assessee.It was no longer open for the respondents to issue the impugned notice under Section 147/148 of the I.T. Act.

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Section 147&148 of the Income Tax Act, 1961 — Reassessment — Since there was full disclosure and in fact, the amount had even become the subject matter of assessment both under section 158BC and section 143(3), there could have been no reason to believe that the income chargeable to tax had indeed escaped assessment, thus, the notice of reassessment was not valid — Audhut Timblo and another vs. Assistant Commissioner of income tax [2020] 420 ITR 62(Bombay)

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