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    <title>2021 (3) TMI 55 - GUJARAT HIGH COURT</title>
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    <description>The court dismissed the writ application challenging the notice for reopening assessment under Section 148 of the Income Tax Act, 1961 for A.Y 2012-13. It held that the notice was not without jurisdiction as the conditions under Section 147 were met. The Assessing Officer independently applied his mind, forming a belief that income had escaped assessment based on verified information. The reasons for reopening were found valid, discrepancies in reassessment figures were rejected, and third-party statements were considered relevant. The sanction for issuing the notice under Section 151 was deemed valid, leading to the dismissal of the applicant&#039;s contentions.</description>
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    <pubDate>Fri, 05 Feb 2021 00:00:00 +0530</pubDate>
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      <description>The court dismissed the writ application challenging the notice for reopening assessment under Section 148 of the Income Tax Act, 1961 for A.Y 2012-13. It held that the notice was not without jurisdiction as the conditions under Section 147 were met. The Assessing Officer independently applied his mind, forming a belief that income had escaped assessment based on verified information. The reasons for reopening were found valid, discrepancies in reassessment figures were rejected, and third-party statements were considered relevant. The sanction for issuing the notice under Section 151 was deemed valid, leading to the dismissal of the applicant&#039;s contentions.</description>
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