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2006 (6) TMI 88 - MADRAS HIGH COURT
Notice u/a 148 - It is well-settled that if a notice under section 148 of the Act has been issued without the jurisdictional foundation under section 147 being available to the Assessing Officer, the notice and the subsequent proceedings will be without jurisdiction, liable to be struck down in exercise of writ jurisdiction of this court - It is a case of absence of material and hence the absence of jurisdiction in the Assessing Officer to initiate the proceedings under section 147/148 - The instant case is a case of mere change of opinion which does not provide jurisdiction to the respondent to initiate proceedings under section 147 - impugned notice under section 147 is quashed