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The contentions of the petitioner in these writ petitions questioning the impugned notice issued under Section 148, are on several grounds, which include that the notice impugned was issued on mere change of opinion and that the same was issued beyond the period of four years. without expressing any view on the merits of the contentions raised by the petitioner against the impugned notice, these writ petitions are disposed of, by granting liberty to the petitioner to give objections to the reasons for reopening, within a period of four weeks from the date of receipt of a copy of this order.

Shanti Prime Publication Pvt. Ltd.

Section 148 of the Income-tax Act, 1961—Income escaping assessment— Assessee has raised several contentions touching upon the merits of the notice issued under Section 148 including the limitation and also by contending that it is based on change of opinion but these contentions cannot be considered at this stage now, since the assessee is bound to give objections to the reasons for reopening and thereafter, the Assessing Officer has to pass a reasoned order and when such course of action is yet to be completed, these writ petitions at this stage cannot be maintained any further,therefore, without expressing any view on the merits of the contentions raised by the assessee against the impugned notice, these writ petitions are disposed of, by granting liberty to the assessee to give objections to the reasons for reopening, within a period of four weeks from the date of receipt of a copy of this order - SESHASAYEE PAPER & BOARDS LTD. V/s DY. CIT - [2020] 269 TAXMAN 120 (MAD)

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