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    <title>2013 (7) TMI 1147 - GUJARAT HIGH COURT</title>
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    <description>The court partially allowed the petition challenging the notice issued under section 148 of the Income-tax Act, 1961 for reopening the assessment. The notice based on diversion of profit by transfer of technology was upheld due to incriminating documents found during a survey. However, the notice regarding the allocation of R&amp;amp;D expenses was not upheld as it was deemed an impermissible attempt to review a previous decision. The Assessing Officer was permitted to proceed with reassessment on the first ground while the interim relief granted on the second ground was confirmed.</description>
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