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2002 (6) TMI 27 - HC - Income TaxReassessment, Condition Precedent - notices under section 148 - petitioner, challenges the said notices on the ground that the requirements under section 147 have not been satisfied and therefore, such notices issued after the expiry of four years from the end of the relevant assessment year in each case, are time barred as in the present case for each of the years there was assessment under sub-section (3) of section 143 of the Income-tax Act. - I am of the opinion that in the absence of satisfaction of one of the statutory requirements as contained in section 147, the notices impugned under section 148 cannot be held to be valid as they were issued after the expiry of four years from the last date of the concerned assessment year and there was an assessment under section 143(3) in respect of the assessee. - Therefore, the notices are barred by time in view of the provision of law as discussed hereinabove. The writ petition is allowed.
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