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2007 (9) TMI 212 - HC - Income TaxAssessee, Non-resident Co. engaged in business of oil & gas exploration – reassessment notice u/s 148 to enhance rate of tax from 55% to 65% – Comm (A) hold that the conditions prescribed in the proviso to section 147 were not fulfilled by AO for initiating the proceedings u/s 147/148 - tribunal also affirmed order of Comm(A) – as there is no failure on part of assessee in disclosing material facts for assessment, reassessment proceedings are barred by limitation of 4 years
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