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2004 (11) TMI 32 - ALLAHABAD HIGH COURTValidity of notices issued u/s 148 - pronouncement by the Supreme Court - assessing authority has furnished reasons and the petitioner has also filed the return. The reasons furnished by the assessing authority do not on their face value hold good for reopening the concluded assessments in view of the subsequent pronouncement by the Supreme Court. The said pronouncement shall be deemed to be operative by fiction of law on the date of assumption of jurisdiction by the assessing authority and the day on which he formed the belief that the income has escaped to assessment - proceedings under section 147 under law cannot be sustained - reassessment notices are totally without jurisdiction hence quashed.
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