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2023 (1) TMI 1269 - ALLAHABAD HIGH COURTRevision u/s 264 - validity of Reopening of assessment u/s 147 - notice u/s 148 was not validly served - HELD THAT:- The assessment order takes note of the fact that the notice issued under section 148 of Income Tax Act was served upon the Assessee and categorical findings has been recorded and the assessment order was passed. As there was no challenge to the findings recorded by the Assessing Authority, the Revisional Authority has not ventured into the arena and has dismissed the revision of the Assessee. The argument raised by the petitioner has no legs to stand as the findings recorded by the Assessing Authority was not put to challenge by the Assessee before any Forum. Raising of plea before this Court under Article 226 of the Constitution of India is not maintainable as the findings recorded by the Assessing Authority was never challenged before the Appellate/Revisional Forum.
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