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2006 (4) TMI 84 - HC - Income TaxJurisdiction to issue notice u/s 148 - applicants had filed separate applications seeking review of the judgment and order dated December 3, 2004 along with an application seeking condonation of delay in filing the review application - court had specifically pointed out to learned counsel for the applicant that there was no averment in the writ petition regarding sanction having been granted by the Additional Commissioner and not by the Joint Commissioner nor was there any averment assailing the notice for non-fulfilment of the provisions of section 151(2) - Challeange to validity of the separate notice issued under section 148 on ground that the said notice is absolutely illegal, arbitrary and had been issued only on account of change of opinion - held that in view of the definition of the words 'Joint Commissioner' in section 2(28C) of the Act, an Additional Commissioner is to be treated as a Joint Commissioner." - we are of the considered opinion that the present applications seeking review of our judgment and order dated December 3, 2004, are not maintainable
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