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    <title>2021 (6) TMI 262 - GUJARAT HIGH COURT</title>
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    <description>The court upheld the validity of the sanction under Section 151 of the Income Tax Act for reopening the assessment, finding that the necessary approval had been obtained. It determined that there were accurate reasons for reopening, based on the assessee&#039;s transactions and information from the Investigation Wing. The court held that there was a valid &quot;reason to believe&quot; that income had escaped assessment, supported by a connection between the information received and material gathered. Additionally, the court rejected the claim of borrowed satisfaction in the reopening process, concluding that the AO had independently assessed the situation. The writ application was dismissed, affirming the justification for reopening the assessment under Section 147 of the Act.</description>
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    <pubDate>Mon, 15 Mar 2021 00:00:00 +0530</pubDate>
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      <title>2021 (6) TMI 262 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=408366</link>
      <description>The court upheld the validity of the sanction under Section 151 of the Income Tax Act for reopening the assessment, finding that the necessary approval had been obtained. It determined that there were accurate reasons for reopening, based on the assessee&#039;s transactions and information from the Investigation Wing. The court held that there was a valid &quot;reason to believe&quot; that income had escaped assessment, supported by a connection between the information received and material gathered. Additionally, the court rejected the claim of borrowed satisfaction in the reopening process, concluding that the AO had independently assessed the situation. The writ application was dismissed, affirming the justification for reopening the assessment under Section 147 of the Act.</description>
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      <pubDate>Mon, 15 Mar 2021 00:00:00 +0530</pubDate>
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