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    <title>2022 (5) TMI 1350 - KARNATAKA HIGH COURT</title>
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    <description>The court quashed the notice issued under Section 148 of the Income-tax Act, 1961, finding it illegal and without jurisdiction as the petitioner had fully disclosed all relevant facts. The court held that the application of Section 56(2)(vii)(c) was baseless. The challenge to the validity of Circulars dated 03.08.2012 and 31.12.2018 was not addressed due to the illegality of the notice. The court determined that the respondents did not have the authority to reopen the assessment beyond the prescribed period of four years as the petitioner had fully disclosed all material facts.</description>
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    <pubDate>Thu, 21 Apr 2022 00:00:00 +0530</pubDate>
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      <description>The court quashed the notice issued under Section 148 of the Income-tax Act, 1961, finding it illegal and without jurisdiction as the petitioner had fully disclosed all relevant facts. The court held that the application of Section 56(2)(vii)(c) was baseless. The challenge to the validity of Circulars dated 03.08.2012 and 31.12.2018 was not addressed due to the illegality of the notice. The court determined that the respondents did not have the authority to reopen the assessment beyond the prescribed period of four years as the petitioner had fully disclosed all material facts.</description>
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