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    <title>1974 (3) TMI 12 - CALCUTTA High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=39527</link>
    <description>Discretionary relief under article 226 was refused because the assessee had taken inconsistent stands on whether the income belonged to him individually or to a Hindu undivided family, pursued the statutory appellate remedy, and then sought writ relief after adverse findings and unexplained delay. The reassessment was also upheld because the reopening notice was issued to the same person and the assessee&#039;s status as individual or Hindu undivided family could be determined in the assessment proceedings; the notice was not invalid merely for failing to specify the capacity in which he was proceeded against. The writ challenge therefore failed and the reassessment was sustained.</description>
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    <pubDate>Mon, 04 Mar 1974 00:00:00 +0530</pubDate>
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      <title>1974 (3) TMI 12 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39527</link>
      <description>Discretionary relief under article 226 was refused because the assessee had taken inconsistent stands on whether the income belonged to him individually or to a Hindu undivided family, pursued the statutory appellate remedy, and then sought writ relief after adverse findings and unexplained delay. The reassessment was also upheld because the reopening notice was issued to the same person and the assessee&#039;s status as individual or Hindu undivided family could be determined in the assessment proceedings; the notice was not invalid merely for failing to specify the capacity in which he was proceeded against. The writ challenge therefore failed and the reassessment was sustained.</description>
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      <pubDate>Mon, 04 Mar 1974 00:00:00 +0530</pubDate>
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