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    <title>2022 (12) TMI 1553 - ITAT AHMEDABAD</title>
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    <description>The court held that the reopening of the tax assessment under section 147 of the Income Tax Act, 1961, was invalid due to non-compliance with procedural requirements under section 151. The Joint Commissioner of Income Tax&#039;s approval was obtained before the reasons for reopening were recorded, indicating a procedural lapse. Consequently, the assessment order under section 147 read with section 143(3) was deemed void ab initio and quashed. The decision emphasizes the necessity of adhering to statutory procedures to ensure assessments are not reopened arbitrarily.</description>
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      <description>The court held that the reopening of the tax assessment under section 147 of the Income Tax Act, 1961, was invalid due to non-compliance with procedural requirements under section 151. The Joint Commissioner of Income Tax&#039;s approval was obtained before the reasons for reopening were recorded, indicating a procedural lapse. Consequently, the assessment order under section 147 read with section 143(3) was deemed void ab initio and quashed. The decision emphasizes the necessity of adhering to statutory procedures to ensure assessments are not reopened arbitrarily.</description>
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