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2023 (8) TMI 1592 - SCH - Income TaxRe-assessment proceedings - validity of fresh notice issued u/s 148 after 4 years when original notice was withdrawn during the judicial proceedings - no clear evidence of withdrawal of earlier notice - original notice was issued within the time limit - should the reassessment process be allowed to continue? - As decided by HC 2018 (5) TMI 1547 - GUJARAT HIGH COURT in absence of withdrawal of the first notice of reassessment the proceedings would survive making the subsequent notice of reopening invalid - HELD THAT - As in terms of Circular No. 17/2019 dated 08.08.2019 issued by Government of India Ministry of Finance Department of Revenue Central Board Direct Taxes Judicial Section since the amount of tax involved is low we are not inclined to interfere with the impugned order. The special leave petitions are accordingly dismissed.
The Supreme Court dismissed SLP (c) No. 28987 of 2018 and SLP(C) No. 184 of 2019 based on Circular No. 17/2019. SLP(C) No. 185 of 2019 and SLP(C) No. 1753 of 2019 were dismissed as withdrawn at the request of counsel Mr. Bhargava V. Desai.
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