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2010 (7) TMI 521 - GUJARAT HIGH COURT
Reassessment - Computing the period between the end of the relevant assessment years and the date of issuance of the notices under section 148, it is evident that the notices have been issued beyond a period of four years from the end of the relevant assessment years - In the absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment years under consideration, the notices under section 148 of the Act having been issued after the expiry of a period of four years from the end of the relevant assessment years, the very initiation of proceedings under section 147 of the Act stand vitiated and as such cannot be sustained - The impugned notices , issued under section 148 of the Income-tax Act, 1961, are hereby quashed and set aside.