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    <title>2018 (9) TMI 878 - DELHI HIGH COURT</title>
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    <description>Reassessment under section 147 read with section 148 was upheld where the Assessing Officer had relevant material indicating non-disclosure of royalty and fee for technical services in the original return, supported by survey and inquiry findings. At the recording stage, only a reasonable belief of escapement was required, and the subsequent objection that tax had been deducted at source did not undo the escapement basis. Later disclosure of the omitted income in response to the section 148 notice also supported the reopening. An incorrect reference to another aspect in the recorded reasons did not vitiate the proceedings where a valid ground for reopening existed.</description>
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