Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Years:2011-12
189 "Merely because an assessee did not repeat the request cannot mean that the assesses waived its right to be provided with the reasons recorded for reopening of the assessment under section 147 of the Income Tax Act, 1961. According to the proviso to section 292BB(1) there is no estoppels against an assessee on account of participating