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2004 (6) TMI 33 - HC - Income TaxNotice u/s 148 - assessments have been sought to be reopened after a period of four years - there is nothing in the reasons recorded to show that the petitioner had failed to disclose truly and fully any income liable to tax for the three assessment years in question - it becomes clear that there cannot be ascribed any failure or omission to the petitioner so as to vest the Assessing Officer with jurisdiction to reopen the assessments which were already finalized - In the light of the fact that the initiation by issuance of impugned notices is beyond the period of four years and the prerequisite conditions stipulated by section 147 of the Act are not fulfilled, there is no case made out for upholding the proposed reassessment. The notices for all the four years are, therefore, bad in law and are quashed and set aside.
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