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2003 (12) TMI 23 - HC - Income Tax
Validity of notice under section 148 – the only ground on which the proceedings under section 147 of the Act had been initiated was that deduction under section 80-O of the Act was admissible at the rate of 50 per cent, of the net receipts and not the gross receipts, as claimed by the assessee. The case of the assessee was that the claim for deduction had duly been examined while making the assessment under section 143(3) of the Act. Thus, the reassessment proceedings were being initiated merely on a change of opinion on the same facts, which is not permissible under the Act after the expiry of four years - Impugned notice cannot be sustained and is, accordingly, quashed