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    <title>2024 (7) TMI 1047 - ITAT DELHI</title>
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    <description>Reopening of assessment under the Income-tax Act was held unsustainable because the recorded reasons contained material factual errors, including incorrect references to the assessment year, the return filed, and alleged TDS details. The reassessment was not based on a live nexus between tangible material and a belief that income had escaped assessment, and the approval under Section 151(1) was treated as mechanical and without proper application of mind. As the jurisdictional foundation itself was defective, the reopening and resulting assessment were quashed; the remaining grounds were left undecided as academic.</description>
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