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    <title>2022 (4) TMI 1083 - ALLAHABAD HIGH COURT</title>
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    <description>The court dismissed the writ petition, upholding the validity of the notice issued under Section 148 of the Income Tax Act. It found that there was prima facie material for the Assessing Officer to reopen the case, emphasizing that the reassessment was based on tangible material indicating income had escaped assessment. The court also ruled that the reassessment was not a result of a mere change of opinion and did not violate CBDT Instruction No. 07 of 2017. Additionally, it concluded that the petitioner had not made a full and true disclosure of all material facts necessary for the assessment, justifying the reassessment.</description>
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    <pubDate>Wed, 20 Apr 2022 00:00:00 +0530</pubDate>
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      <description>The court dismissed the writ petition, upholding the validity of the notice issued under Section 148 of the Income Tax Act. It found that there was prima facie material for the Assessing Officer to reopen the case, emphasizing that the reassessment was based on tangible material indicating income had escaped assessment. The court also ruled that the reassessment was not a result of a mere change of opinion and did not violate CBDT Instruction No. 07 of 2017. Additionally, it concluded that the petitioner had not made a full and true disclosure of all material facts necessary for the assessment, justifying the reassessment.</description>
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