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    <title>2022 (9) TMI 814 - ITAT CHENNAI</title>
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    <description>The Tribunal invalidated the reopening of assessment under Section 147 of the Income Tax Act, as the reasons lacked allegations of non-disclosure by the assessee, required for such action after four years. The sanction under Section 151 was deemed invalid due to a mechanical approval lacking detailed reasoning. The Tribunal did not address the validity of additions for bogus purchases on merits, as the assessment order was quashed on legal grounds, leading to the dismissal of these grounds. The Tribunal emphasized the need for specific allegations in reopening assessments and reasoned satisfaction in sanctions under the Income Tax Act.</description>
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      <description>The Tribunal invalidated the reopening of assessment under Section 147 of the Income Tax Act, as the reasons lacked allegations of non-disclosure by the assessee, required for such action after four years. The sanction under Section 151 was deemed invalid due to a mechanical approval lacking detailed reasoning. The Tribunal did not address the validity of additions for bogus purchases on merits, as the assessment order was quashed on legal grounds, leading to the dismissal of these grounds. The Tribunal emphasized the need for specific allegations in reopening assessments and reasoned satisfaction in sanctions under the Income Tax Act.</description>
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