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    <title>2024 (9) TMI 1134 - PATNA HIGH COURT</title>
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    <description>The HC upheld the validity of a notice issued under Section 148 for reopening assessment beyond four years. The court held that the AO had properly recorded reasons for believing income escaped assessment, which were submitted to the Commissioner for approval. The Commissioner&#039;s written order expressing satisfaction with the AO&#039;s recorded reasons was sufficient to meet Section 151 requirements. The court clarified that the Commissioner need not record separate reasons but must only express satisfaction with the AO&#039;s reasons. The writ petition challenging the notice was dismissed as the statutory requirements were adequately fulfilled.</description>
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    <pubDate>Thu, 12 Sep 2024 00:00:00 +0530</pubDate>
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      <title>2024 (9) TMI 1134 - PATNA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=758890</link>
      <description>The HC upheld the validity of a notice issued under Section 148 for reopening assessment beyond four years. The court held that the AO had properly recorded reasons for believing income escaped assessment, which were submitted to the Commissioner for approval. The Commissioner&#039;s written order expressing satisfaction with the AO&#039;s recorded reasons was sufficient to meet Section 151 requirements. The court clarified that the Commissioner need not record separate reasons but must only express satisfaction with the AO&#039;s reasons. The writ petition challenging the notice was dismissed as the statutory requirements were adequately fulfilled.</description>
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      <pubDate>Thu, 12 Sep 2024 00:00:00 +0530</pubDate>
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