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2006 (2) TMI 113 - BOMBAY HIGH COURTNotices issued under section 148 - reopening of the assessments - where the assessment is sought to be reopened beyond four years from the end of the relevant assessment year, then, unless it is established that there was failure on the part of the assessee to disclose fully and truly all material facts the question of invoking Explanation 2 to section 147 does not arise at all - notices issued for the reopening of the assessments do not fulfil the preconditions required to be fulfilled for reopening the assessment. Accordingly, we quash and set aside the impugned notices issued under section 148 of the Income-tax Act, 1961
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