Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]
151 of the Act which in considered view is not a procedural matter but certainly goes to the root of the re- AYs: 2008-09 & 2009-10 M/s Om Dayal Ingots & Steel co. Pvt. Ltd. opening of assessment. Accordingly we hold the proceedings as invalidly initiated and accordingly the re-assessment proceedings as well as consequent order are quashed. Ground