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    <title>2021 (5) TMI 840 - GUJARAT HIGH COURT</title>
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    <description>The court dismissed the writ application, upholding the validity of the sanction under Section 151 of the Income Tax Act and the accuracy of the reasons for reopening the assessment. It found that there was a &#039;reason to believe&#039; that income chargeable to tax had escaped assessment, with a connection established between the information received and the material gathered. The court deemed the reopening permissible for inquiry and not based on borrowed satisfaction, concluding that the Assessing Officer had sufficient grounds to initiate proceedings under Section 147 of the Act.</description>
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      <description>The court dismissed the writ application, upholding the validity of the sanction under Section 151 of the Income Tax Act and the accuracy of the reasons for reopening the assessment. It found that there was a &#039;reason to believe&#039; that income chargeable to tax had escaped assessment, with a connection established between the information received and the material gathered. The court deemed the reopening permissible for inquiry and not based on borrowed satisfaction, concluding that the Assessing Officer had sufficient grounds to initiate proceedings under Section 147 of the Act.</description>
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