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    <title>2021 (4) TMI 92 - GUJARAT HIGH COURT</title>
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    <description>The court upheld the reopening of the assessment, finding it justified based on new tangible material received by the assessing officer beyond four years. The court determined that the assessing officer independently verified the information, conducted necessary inquiries, and had a reasonable belief that income had escaped assessment. Claims of change of opinion, borrowed satisfaction, and conjectures were dismissed as the court found them lacking merit. The writ application was dismissed, and the impugned notice and order disposing of objections were upheld.</description>
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      <description>The court upheld the reopening of the assessment, finding it justified based on new tangible material received by the assessing officer beyond four years. The court determined that the assessing officer independently verified the information, conducted necessary inquiries, and had a reasonable belief that income had escaped assessment. Claims of change of opinion, borrowed satisfaction, and conjectures were dismissed as the court found them lacking merit. The writ application was dismissed, and the impugned notice and order disposing of objections were upheld.</description>
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