S. 147 : Reassessment-Notice-Sale of investment in Indian company by Assessee, a tax resident of Mauritius-No return filed as capital gain was exempt in terms of Article 13(4) of the DTAA-Reopening on the basis of form 15CA filed by the Assessee-No prima facie satisfaction was recorded-Notice and the consequent reassessment order is set aside-DTAA-India-Mauritius.[S. 148, Form 15CA, Art. 13(4)]