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    <title>1971 (2) TMI 3 - CALCUTTA High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=8137</link>
    <description>The court quashed the impugned notices issued by the Income-tax Officer under sections 148 and 147(b) of the Income-tax Act, 1961, for reopening assessments. The court held that the conditions precedent for issuing the notices were not met, as the information relied upon lacked a real connection to the petitioner&#039;s income and was not valid under section 147(b). The court found that the Income-tax Officer&#039;s belief was merely a change of opinion, not based on reasonable belief, and thus concluded that the notices were issued without jurisdiction. Consequently, the court granted the writ petition, quashed the notices, and made the rule absolute without costs.</description>
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    <pubDate>Thu, 04 Feb 1971 00:00:00 +0530</pubDate>
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      <title>1971 (2) TMI 3 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8137</link>
      <description>The court quashed the impugned notices issued by the Income-tax Officer under sections 148 and 147(b) of the Income-tax Act, 1961, for reopening assessments. The court held that the conditions precedent for issuing the notices were not met, as the information relied upon lacked a real connection to the petitioner&#039;s income and was not valid under section 147(b). The court found that the Income-tax Officer&#039;s belief was merely a change of opinion, not based on reasonable belief, and thus concluded that the notices were issued without jurisdiction. Consequently, the court granted the writ petition, quashed the notices, and made the rule absolute without costs.</description>
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      <pubDate>Thu, 04 Feb 1971 00:00:00 +0530</pubDate>
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