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    <title>2021 (8) TMI 379 - GUJARAT HIGH COURT</title>
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    <description>The court dismissed the petition challenging the reopening of the assessment under Section 148 of the Income Tax Act, 1967. It held that the respondent authority had jurisdiction to reopen the assessment based on tangible material obtained during an inquiry, including evidence of accommodation entries. The court found that the income chargeable to tax had indeed escaped assessment, and the procedural requirements for reopening the assessment were met. The Assessing Officer&#039;s belief at the initiation stage did not require established facts of income escapement, and the court emphasized the statutory function of forming a prima facie belief.</description>
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    <pubDate>Sat, 31 Jul 2021 00:00:00 +0530</pubDate>
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      <description>The court dismissed the petition challenging the reopening of the assessment under Section 148 of the Income Tax Act, 1967. It held that the respondent authority had jurisdiction to reopen the assessment based on tangible material obtained during an inquiry, including evidence of accommodation entries. The court found that the income chargeable to tax had indeed escaped assessment, and the procedural requirements for reopening the assessment were met. The Assessing Officer&#039;s belief at the initiation stage did not require established facts of income escapement, and the court emphasized the statutory function of forming a prima facie belief.</description>
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