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2004 (2) TMI 54 - HC - Income TaxNotice u/s 148 for reopening of assessment - Upon a careful perusal of order of AO one does not find that the Assessing Officer has reached his satisfaction that the reason for reopening the assessment, is due to the failure on the part of the assessee to make a return under section 139 - Even the Commissioner has not recorded anywhere that there was a failure on the part of the assessee/petitioner to assume jurisdiction for reopening under section 147 – Notice after a lapse of four years is not valid so it is quashed
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