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    <title>2021 (8) TMI 620 - GUJARAT HIGH COURT</title>
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    <description>The court dismissed the petition, upholding the validity of the notice issued under Section 148 of the Income Tax Act. The reopening of assessment was deemed justified as it was based on tangible material received from the Investigation Wing, revealing that the petitioner had received accommodation entries from shell companies. Additionally, the court found that the petitioner had failed to disclose all material facts necessary for assessment, warranting the reopening beyond the four-year period.</description>
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      <description>The court dismissed the petition, upholding the validity of the notice issued under Section 148 of the Income Tax Act. The reopening of assessment was deemed justified as it was based on tangible material received from the Investigation Wing, revealing that the petitioner had received accommodation entries from shell companies. Additionally, the court found that the petitioner had failed to disclose all material facts necessary for assessment, warranting the reopening beyond the four-year period.</description>
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