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2005 (2) TMI 46 - HC - Income Tax
Validity and/or legality of the notices issued under section 148 - petitioners submit that all the notices and the proceedings initiated thereunder are without jurisdiction and illegal since none of the conditions precedent for assumption of the jurisdiction u/s 147 have been satisfied - It is evident that even according to the Central Board of Direct Taxes, a mere change of opinion cannot form the basis for reopening a completed assessment – petition allowed – notices are quashed