Reassessment for taxing Royalty at higher rate due to change in opinion not valid

The assessment under Section 143(3) was originally done on 19.12.2008. The notice under Section 148, which is impugned herein, has been issued beyond the period of four years from the end of the relevant assessment year. The reasons for initiating the reassessment proceedings which were supplied to the petitioner on 16.01.2014 are as under:-

Reasons for issue of notice u/s 148 of the Income Tax Act, 1961 :-

Return declaring Nil in

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