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    <title>2024 (10) TMI 713 - Supreme Court</title>
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    <description>Reopening of assessment under the reassessment framework was challenged on the grounds that approval under section 151 reflected non-application of mind and that no personal hearing was granted before the section 148A(d) order where requested. The cited High Court view noted that a careful reading of the approval form with the draft order would have shown no material to treat it as a fit case for notice or for an order under section 148A(d), and that a personal hearing should be given if sought. In the Supreme Court, the special leave petition was dismissed because the 201-day delay in filing was not satisfactorily explained and condonation was refused.</description>
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      <title>2024 (10) TMI 713 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=760114</link>
      <description>Reopening of assessment under the reassessment framework was challenged on the grounds that approval under section 151 reflected non-application of mind and that no personal hearing was granted before the section 148A(d) order where requested. The cited High Court view noted that a careful reading of the approval form with the draft order would have shown no material to treat it as a fit case for notice or for an order under section 148A(d), and that a personal hearing should be given if sought. In the Supreme Court, the special leave petition was dismissed because the 201-day delay in filing was not satisfactorily explained and condonation was refused.</description>
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