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The HC held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
The HC held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
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