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of HC held that the notice u/s 148 was time-barred under Section 149(1), rendering it invalid. The Assessing Officer (AO) exceeded statutory limitations by issuing a notice beyond the prescribed time period. The court emphasized that procedural timelines are mandatory and cannot be circumvented. The impugned notice was liable to be set aside solely on the ground of limitation, irrespective of other substantive challenges. The decision underscores the critical importance of adhering to statutory time constraints in tax reassessment proceedings, affirming that procedural compliance is essential for maintaining the integrity of tax assessment processes.
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