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2005 (3) TMI 63 - GAUHATI HIGH COURT
Challenge to the notices issued under section 148, purportedly initiating a proceeding/action under section 147 thereof on the ground that the income of the assessees/writ petitioners as computed therein had escaped assessment - notices admittedly do not exhibit as to what material facts were not truly and fully disclosed by the assessees necessary for assessment - The returns admittedly mention about the cess on green leaves paid and deductions as permissible were allowed. In view of the exposition of law on the point mentioned hereinabove, the inescapable conclusion is that the impugned notices are also not sustainable being barred by time. - impugned notices being illegal and without jurisdiction are quashed.