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    <title>2024 (5) TMI 1629 - PATNA HIGH COURT</title>
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    <description>HC held that the limitation in s.149 for issuance of notice under s.148 is three years except where escaped tax exceeds Rs.50 lakhs. Here the total assessment was ~Rs.31 lakhs and demand ~Rs.19 lakhs, so the ten-year limb did not apply. The post-2021 procedure under s.148A (requiring disclosure of material and opportunity before issuing s.148 notice) was not complied with; the SC&#039;s remedial directions to supply material within 30 days were ignored and the s.148A notice was issued belatedly. Re-assessment under s.148 was therefore disallowed.</description>
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    <pubDate>Mon, 06 May 2024 00:00:00 +0530</pubDate>
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      <title>2024 (5) TMI 1629 - PATNA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=464461</link>
      <description>HC held that the limitation in s.149 for issuance of notice under s.148 is three years except where escaped tax exceeds Rs.50 lakhs. Here the total assessment was ~Rs.31 lakhs and demand ~Rs.19 lakhs, so the ten-year limb did not apply. The post-2021 procedure under s.148A (requiring disclosure of material and opportunity before issuing s.148 notice) was not complied with; the SC&#039;s remedial directions to supply material within 30 days were ignored and the s.148A notice was issued belatedly. Re-assessment under s.148 was therefore disallowed.</description>
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      <pubDate>Mon, 06 May 2024 00:00:00 +0530</pubDate>
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