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<h1>Invalidity of Summary Assessment under Indian Income Tax Act for Lack of Section 22(4) Notice</h1> The High Court of Patna held that a summary assessment under Section 23, Clause (4) of the Indian Income Tax Act is invalid if a notice under Section ... - The High Court of Patna ruled that a summary assessment under Section 23, Clause (4) of the Indian Income Tax Act is not valid if a notice under Section 22(4) was not issued before the filing of the return. The court found that in the case at hand, there was no breach of a notice under Section 22(4) as the notice in question may have been under a different section. Therefore, the summary assessment was deemed illegal, and the assessee was awarded costs.