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    <title>2006 (11) TMI 165 - CALCUTTA High Court</title>
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    <description>The HC allowed the writ application, setting aside the impugned notice under section 148 of the Income-tax Act, 1961, issued for the assessment year 1994-95. The court held that the action was barred by limitation, as it was not initiated within four years from the end of the relevant assessment year. The court found that the reopening of the assessment was unjustified, as it was based on calculation errors and a change of opinion, without valid reasons initially provided. The judgment emphasized the necessity of adhering to statutory limitations and procedural fairness.</description>
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