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1998 (11) TMI 72 - HC - Income TaxExtract: .......ormation of subjective belief in such a case cannot be sustained. The conclusion is irresistible that action under section 147 has been initiated de hors the provisions of section 32AB of the Income-tax Act which makes it ultra vires and void. As a result, the impugned notices are quashed. Rule is made absolute. There shall be no order as to costs.
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