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In the matters of reopening the AO is duty bound to provide copy of the satisfaction note and order of the Principal Commissioner, who granted approval to issuance of the notice with the note of the Assessing Officer in support of his request of approval. So much so that the Court in (2023] 455 ITR 92 (Bom) held that non furnishing of the same will be a contravention of the provisions of article 14 of the Constitution of India.

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