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    <title>2016 (7) TMI 929 - GUJARAT HIGH COURT</title>
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    <description>The court upheld the validity of the notice for reopening the assessment, dismissing the petition challenging it. It emphasized that reassessment should be based on the material that surfaces during assessment, independent of court observations. The court found that the Assessing Officer had sufficient grounds to form a belief of income escapement, including the assessee&#039;s failure to fully disclose material facts. The reliance on the investigation wing&#039;s report was deemed acceptable, as the Assessing Officer independently applied his mind to the findings.</description>
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      <description>The court upheld the validity of the notice for reopening the assessment, dismissing the petition challenging it. It emphasized that reassessment should be based on the material that surfaces during assessment, independent of court observations. The court found that the Assessing Officer had sufficient grounds to form a belief of income escapement, including the assessee&#039;s failure to fully disclose material facts. The reliance on the investigation wing&#039;s report was deemed acceptable, as the Assessing Officer independently applied his mind to the findings.</description>
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