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    <title>2025 (8) TMI 429 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad held that the AO did not derive primary satisfaction for reopening the assessment, as the reasons recorded were factually incorrect and based on a failure to properly examine the return of income filed by the assessee. The AO&#039;s conclusion of escapement of income was not supported by the material on record. Consequently, the reopening was quashed on factual grounds, and the appeal of the assessee was allowed without addressing the merits of the case.</description>
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      <description>The ITAT Ahmedabad held that the AO did not derive primary satisfaction for reopening the assessment, as the reasons recorded were factually incorrect and based on a failure to properly examine the return of income filed by the assessee. The AO&#039;s conclusion of escapement of income was not supported by the material on record. Consequently, the reopening was quashed on factual grounds, and the appeal of the assessee was allowed without addressing the merits of the case.</description>
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