Reassessment u/s 148: Court Dismisses Writ Petitions Challenging Jurisdiction and Time Limits in Tax Notices.

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....Reassessment u/s 148 - time limit for notice - change of opinion - case on hand is one that of the mixed question of law and facts - AO is empowered to consider the issue relating to jurisdiction, time limit and all other legal grounds raised by the writ petitioner at the time of passing the final orders - writ petitions dismissed....