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    <title>2006 (6) TMI 144 - ITAT DELHI-A</title>
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    <description>The Tribunal allowed the Department&#039;s appeal, determining that the reopening of the assessment under section 148 of the Income-tax Act, 1961, was valid. It concluded that the Assessing Officer possessed &quot;reason to believe&quot; rather than merely &quot;reason to suspect&quot; that income had escaped assessment. The Tribunal found that the procedural requirements, including the recording and communication of reasons, service of notice, and the necessity of approval under section 151(1), were satisfied. Consequently, the case was remanded to the CIT(A) for a decision on the merits, as the initial appeal did not address the substantive issues.</description>
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      <title>2006 (6) TMI 144 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63256</link>
      <description>The Tribunal allowed the Department&#039;s appeal, determining that the reopening of the assessment under section 148 of the Income-tax Act, 1961, was valid. It concluded that the Assessing Officer possessed &quot;reason to believe&quot; rather than merely &quot;reason to suspect&quot; that income had escaped assessment. The Tribunal found that the procedural requirements, including the recording and communication of reasons, service of notice, and the necessity of approval under section 151(1), were satisfied. Consequently, the case was remanded to the CIT(A) for a decision on the merits, as the initial appeal did not address the substantive issues.</description>
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