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2004 (2) TMI 40 - BOMBAY HIGH COURT
Notice u/s 148 - whether there was any failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment - Assessing Officer arrived at the conclusion that there is failure on the part of the assessee to disclose fully and truly all material facts solely on the ground that the assessee had claimed in its return of income depreciation at 40 per cent, on leased vehicles instead of depreciation at 20 per cent - There being no failure on the part of the assessee to disclose fully and truly all material facts, the impugned notices issued beyond the period of four years from the end of the relevant assessment years, are liable to be held to have been issued in contravention of the provision of the Income-tax Act. – Notices are quashed