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The High Court of Madras held that a combined notice under Sections 23(2) and 22(4) is valid, and non-compliance can justify assessment under Section 23(4). An assessee can be assessed under Section 23(4) even if a notice under Section 22(4) is issued and not under Section 23(2). The court ruled against the petitioner, who was directed to pay the costs of the reference amounting to Rs. 250.
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