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2004 (4) TMI 44 - ALLAHABAD HIGH COURT
Reassessment notice - it is evident that the question about the entries in the name of the petitioner-Hindu undivided family standing in the books of the firm, M/s. Atul Traders or M/s. Atul Industrial Corporation, have been fully investigated by the Assessing Officer, and only after such investigation he has come to the opinion that these were bogus entries. - Thus, it is obvious that the impugned notice under section 148 has been issued only on the basis of a change of opinion on the part of the Assessing Officer, which is illegal. - the impugned notices are quashed