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2009 (9) TMI 647 - AT - Income TaxReassessment - Addition - Notice u/s 148 - Computation of period of four years - Held that:- the observation of the CIT(A) is patently not correct and against the provisions of law. - four years have to be counted from the end of the assessment year and not from the date of passing of the assessment order as stated by the CIT(A). In the instant case, admittedly, the assessment year ended on 31st March. 1996 and, therefore, the notice issued on 20th March, 2002 under s. 148 was served upon the assessee on 28th March, 2002 was beyond four years from the end the assessment year. Change of opinion - Reason to believe - assessee had disclosed and specific information was submitted at the time of original assessment proceedings. - the reopening of the assessment, in the instant case was bad in law and thus, the consequential order passed under s. 143(3) r/w s. 147 of the Act dt. 30th Sept., 2002 is liable to be quashed.
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