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2008 (6) TMI 137 - GUJARAT HIGH COURTPetition challenges notice issued u/s 148 – no failure on part of the assessee to fully and truly disclose all material facts relevant for the assessment – it is a case wherein the AO has formed an incorrect opinion as per opinion of the successor AO - hence, the successor AO cannot treat the assessee to be in default of non-disclosure - admittedly the impugned notice is issued beyond a period of four years from the end of the relevant Assessment Year the said notice is required to be quashed
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