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2018 (6) TMI 1175 - AT - Income TaxValidity of reopening of assessment beyond 4 years - capital gains - reasons to believe - assumption of the fact - proof of filing of return - there is no mention that income amounting to ₹ 1 lac or more is believed to have escaped assessment - Held that:- In the absence of anything in the reasons recorded to suggest that the income chargeable to tax which has escaped assessment is one lac rupees or more, the notice issued u/s 148 of the Act beyond four years of the end of the relevant assessment year, is invalid. See MAHESH KUMAR GUPTA VERSUS COMMISSIONER OF INCOME TAX & ANOTHER [2013 (4) TMI 444 - ALLAHABAD HIGH COURT] - Decided in favour of assessee.
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