2021 (3) TMI 1394

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..... such reopening in the body of the order itself. The reasons cannot be supplied later. If the reason is simply due to the objection raised by the A.G., Odisha , it must state what the nature of such objection was. Only then will the assessee be in a position to answer the notice issued effectively. Since this basic principle has not been adhered to, the Court sets aside the impugned order reopenin .....

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..... otice to appear and in the note call, again reference simply is made to report receipt from A.G., Odisha, Bhubaneswar on 6th November, 2012 without actually indicating what was in the said objection raised by the A.G., Odisha. 3. An order reopening the assessment must reflect the reasons for such reopening in the body of the order itself. The reasons cannot be supplied later. If the reason is s .....

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