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    <title>2004 (9) TMI 26 - DELHI High Court</title>
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    <description>The court held that the notice issued under Section 148 of the Income-tax Act was invalid as it was based on a mere change of opinion without valid reasons to believe that income had escaped assessment. The Assessing Officer had not independently assessed the situation but relied on an audit objection, which was not a lawful basis for reopening the assessment. Consequently, the court allowed the petition, quashed the notice, and awarded costs to the petitioner.</description>
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      <description>The court held that the notice issued under Section 148 of the Income-tax Act was invalid as it was based on a mere change of opinion without valid reasons to believe that income had escaped assessment. The Assessing Officer had not independently assessed the situation but relied on an audit objection, which was not a lawful basis for reopening the assessment. Consequently, the court allowed the petition, quashed the notice, and awarded costs to the petitioner.</description>
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