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    <title>2012 (12) TMI 690 - GUJARAT HIGH COURT</title>
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    <description>The court held that the notice issued under Section 148 of the Income Tax Act to reopen the assessment was illegal as the conditions for reopening were not met. The court found that the Assessing Officer did not have new material to justify the reopening and that the alleged failure to disclose material facts was unfounded. The court concluded that the Assessing Officer overlooked basic accounting principles and quashed the notice, setting aside all subsequent actions and orders.</description>
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      <link>https://www.taxtmi.com/caselaws?id=219675</link>
      <description>The court held that the notice issued under Section 148 of the Income Tax Act to reopen the assessment was illegal as the conditions for reopening were not met. The court found that the Assessing Officer did not have new material to justify the reopening and that the alleged failure to disclose material facts was unfounded. The court concluded that the Assessing Officer overlooked basic accounting principles and quashed the notice, setting aside all subsequent actions and orders.</description>
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