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1972 (3) TMI 20 - HC - Income TaxNotice under section 148 - petitioner, therefore, submits that the purported action of the respondent No. 1 to assess the salary income of the petitioner on " due basis " and not on " actual receipt basis " is amounting to and/or will amount to a mere change of opinion and, as such, the respondent No. 1 had no competence, jurisdiction or authority to initiate the purported reassessment proceeding under section 148 - petitioner also contended that the purported notice under section 148 of the Act dated 30th March, 1971, which was served upon the petitioner on the 1st April, 1971, as alleged by him, is barred by limitation and that the said notice for reassessment for the assessment year 1962-63, was issued in violation of section 149 of the Act.
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