2019 (12) TMI 266

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....anty for the respondent nos. 1 and 2 P.C. 1. Heard. Rule. 2. This petition challenges a notice dated 20th March, 2019 issued under Section 148 of the Income Tax Act, 1961 (the Act) seeking to reopen the assessment for Assessment Year 2012-13. The impugned notice is beyond the period of 4 years from the end of the relevant assessment year as the assessment was completed under Section 143(3....

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....o examination during regular assessment proceedings leading to an order under Section 143(3) of the Act. The respondents have not disputed the same. 3. In the above view, a prima facie case has been made out by the petitioner that the above indicates non-application of mind to the facts in issuing the impugned notice and also a case of change of opinion. Thus, the Assessing Officer could not ha....