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2005 (8) TMI 68 - HC - Income TaxNotice under section 148 - Since the reopening is beyond the period of four years, in the absence of any material to show that there is failure on the part of the assessee to disclose fully and truly all material facts, the reopening of the assessment cannot be sustained - mere fact that a protective assessment has been made in the case of some other assessee on the ground that the income of that assessee is assessable in the hands of the assessee herein cannot be a ground to reopen the concluded assessment of the assessee - notices issued are without jurisdiction and the same are liable to be quashed and set aside
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