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    <title>2013 (7) TMI 1146 - GUJARAT HIGH COURT</title>
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    <description>The court partly allowed the petition challenging the validity of reopening the assessment under section 148 of the Income-tax Act, 1961. The notice for reopening based on the diversion of profits by transferring technology was upheld, as the court found sufficient reason to believe income had escaped assessment. However, the notice regarding the allocation of Research &amp;amp; Development expenses was quashed, as it was deemed an impermissible attempt to review a previously settled issue. The Assessing Officer was permitted to proceed with reassessment on the ground of profit diversion.</description>
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