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2018 (3) TMI 1468 - HC - Income TaxReopening of assessment - notice was not issued within the time limit - Held that:- Permanent Account Numbers issued. The notices were dispatched at the address which was available in the system of the department. The petitioner had never applied for change of address and, therefore, the department was obviously not aware about it. These are disputed questions of facts. Whether the system of the department contains the petitioner's old address as declared by him earlier and, therefore, the department was correct in sending the notice to such address would need proper examination. The petitioner's contention that without the change of the address, the system would not accept the petitioner's returns declaring new address also cannot be brushed aside. These are issues we are not inclined to go in a writ petition. These issues need to be gone into in the departmental proceedings in regular assessments. The authorities would have sufficient time and opportunity to examine such disputed questions.
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