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    <title>2012 (7) TMI 806 - DELHI HIGH COURT</title>
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    <description>The court allowed the writ petition, quashing the impugned reassessment notice and proceedings. It held that Section 172 does not preclude the applicability of Sections 147/148, emphasizing that Section 172(4) is a summary procedure. The court also determined that the &#039;annual no objection certificate&#039; issued under the DTAA between India and UAE does not prevent reassessment. Additionally, it found the reasons recorded by the Assessing Officer for reassessment were insufficient as they were based on assumptions rather than concrete evidence, not meeting the requirements of Section 147.</description>
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    <pubDate>Thu, 26 Jul 2012 00:00:00 +0530</pubDate>
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      <title>2012 (7) TMI 806 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=215308</link>
      <description>The court allowed the writ petition, quashing the impugned reassessment notice and proceedings. It held that Section 172 does not preclude the applicability of Sections 147/148, emphasizing that Section 172(4) is a summary procedure. The court also determined that the &#039;annual no objection certificate&#039; issued under the DTAA between India and UAE does not prevent reassessment. Additionally, it found the reasons recorded by the Assessing Officer for reassessment were insufficient as they were based on assumptions rather than concrete evidence, not meeting the requirements of Section 147.</description>
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      <pubDate>Thu, 26 Jul 2012 00:00:00 +0530</pubDate>
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