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    <title>2021 (1) TMI 788 - GUJARAT HIGH COURT</title>
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    <description>The Court held that the re-opening of the assessment beyond the four-year period was not justified as the material facts were not fully disclosed, and there was no tangible evidence of income escapement. The Court referred to the partnership agreement, emphasizing that the partners&#039; decision not to pay interest and remuneration, as per the deed, could lead to deletion of disallowance. Relying on precedent, the Court dismissed the appeal, quashed the notice under Section 148 of the Income Tax Act, and terminated all consequential proceedings, ruling in favor of the writ-applicant.</description>
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    <pubDate>Thu, 07 Jan 2021 00:00:00 +0530</pubDate>
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      <description>The Court held that the re-opening of the assessment beyond the four-year period was not justified as the material facts were not fully disclosed, and there was no tangible evidence of income escapement. The Court referred to the partnership agreement, emphasizing that the partners&#039; decision not to pay interest and remuneration, as per the deed, could lead to deletion of disallowance. Relying on precedent, the Court dismissed the appeal, quashed the notice under Section 148 of the Income Tax Act, and terminated all consequential proceedings, ruling in favor of the writ-applicant.</description>
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      <pubDate>Thu, 07 Jan 2021 00:00:00 +0530</pubDate>
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