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    <title>2022 (8) TMI 964 - GUJARAT HIGH COURT</title>
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    <description>The court upheld the validity of the notice issued under Section 148 of the Income Tax Act, 1961, rejecting the writ application. The reopening was deemed valid as it was based on tangible information obtained during a survey, not constituting a fishing expedition. The court dismissed the argument regarding compliance with Instruction No.1/2011, clarifying its inapplicability to Section 148 proceedings. Additionally, it found that the Assessing Officer adequately applied his mind and had reasonable grounds for reopening the assessment, based on sufficient material.</description>
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      <description>The court upheld the validity of the notice issued under Section 148 of the Income Tax Act, 1961, rejecting the writ application. The reopening was deemed valid as it was based on tangible information obtained during a survey, not constituting a fishing expedition. The court dismissed the argument regarding compliance with Instruction No.1/2011, clarifying its inapplicability to Section 148 proceedings. Additionally, it found that the Assessing Officer adequately applied his mind and had reasonable grounds for reopening the assessment, based on sufficient material.</description>
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