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Disposed off.The notice issued to the assessee and the supporting reasons did not invoke provisions of the second proviso of Section 147 of the Act and therefore at this stage the revenue cannot be permitted to take benefit of the second proviso.

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Sec. 147 of Income Tax Act, 1961—Reassessment —NEW DELHI TELEVISION LTD. vs. Deputy CIT.[2020] 24 ITCD Online 002 (SC)