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    <title>2021 (10) TMI 427 - BOMBAY HIGH COURT</title>
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    <description>The court quashed the notices issued under Section 148 of the Income Tax Act, ruling that they were based on incorrect assumptions and lacked jurisdictional parameters. It emphasized that reasons for reopening assessments must be based on tangible material and cogent facts, and cannot be supplemented later. The court found the reasons recorded by the assessment officer were erroneous and did not directly support the belief that taxable income had escaped assessment.</description>
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      <description>The court quashed the notices issued under Section 148 of the Income Tax Act, ruling that they were based on incorrect assumptions and lacked jurisdictional parameters. It emphasized that reasons for reopening assessments must be based on tangible material and cogent facts, and cannot be supplemented later. The court found the reasons recorded by the assessment officer were erroneous and did not directly support the belief that taxable income had escaped assessment.</description>
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