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    <title>2021 (6) TMI 103 - GUJARAT HIGH COURT</title>
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    <description>The court dismissed the writ application, upholding the reopening of the assessment. It found that the Assessing Officer had sufficient material and reasons to believe that income had escaped assessment. Emphasizing that the AO&#039;s belief is administrative and does not require final adjudication at the notice stage, the court held that the necessary sanction under Section 151 was obtained, and there was a live link between the information received and material gathered. Consequently, the court upheld the reopening and dismissed the writ application.</description>
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      <title>2021 (6) TMI 103 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=408207</link>
      <description>The court dismissed the writ application, upholding the reopening of the assessment. It found that the Assessing Officer had sufficient material and reasons to believe that income had escaped assessment. Emphasizing that the AO&#039;s belief is administrative and does not require final adjudication at the notice stage, the court held that the necessary sanction under Section 151 was obtained, and there was a live link between the information received and material gathered. Consequently, the court upheld the reopening and dismissed the writ application.</description>
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      <pubDate>Mon, 15 Mar 2021 00:00:00 +0530</pubDate>
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