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    <title>2022 (4) TMI 506 - GUJARAT HIGH COURT</title>
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    <description>The court upheld the legitimacy of reopening the assessment under Section 148 of the Income Tax Act, finding that the Assessing Officer had tangible material to reasonably believe that income had escaped assessment. The court also determined that the assessee had not fully and truly disclosed material facts, justifying the reopening beyond the four-year period. The reliance on a statement from Shri Bijal Ashok Shah was deemed valid as tangible material for reopening, and the court confirmed that the reassessment was not based on a mere change of opinion but on new tangible material. Additionally, the court found that the procedural requirements for reopening the assessment were duly followed, ultimately rejecting the challenge against the reopening.</description>
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    <pubDate>Tue, 22 Mar 2022 00:00:00 +0530</pubDate>
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      <title>2022 (4) TMI 506 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=420840</link>
      <description>The court upheld the legitimacy of reopening the assessment under Section 148 of the Income Tax Act, finding that the Assessing Officer had tangible material to reasonably believe that income had escaped assessment. The court also determined that the assessee had not fully and truly disclosed material facts, justifying the reopening beyond the four-year period. The reliance on a statement from Shri Bijal Ashok Shah was deemed valid as tangible material for reopening, and the court confirmed that the reassessment was not based on a mere change of opinion but on new tangible material. Additionally, the court found that the procedural requirements for reopening the assessment were duly followed, ultimately rejecting the challenge against the reopening.</description>
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