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    <title>Reassessment Approval Flaws: Court Criticizes Inadequate Evaluation by Tax Officers in Income Tax Act Section 147 Case.</title>
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    <description>Reopening of assessment u/s 147 - Whether the PCIT applied his mind while granting approval? - Senior officers like ACIT and PCIT are expected to apply their minds to such requests and, only after that, approve the initiation of reassessment proceedings. Several pitfalls that the Court&#039;s notice can be avoided if the concerned authorities were to look closely at the request made for re-opening. Clearly, in SIPL’s case, these aspects were not examined by the concerned AO or by the ACIT/PCIT. - HC</description>
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      <description>Reopening of assessment u/s 147 - Whether the PCIT applied his mind while granting approval? - Senior officers like ACIT and PCIT are expected to apply their minds to such requests and, only after that, approve the initiation of reassessment proceedings. Several pitfalls that the Court&#039;s notice can be avoided if the concerned authorities were to look closely at the request made for re-opening. Clearly, in SIPL’s case, these aspects were not examined by the concerned AO or by the ACIT/PCIT. - HC</description>
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