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    <title>2026 (5) TMI 333 - SC Order</title>
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    <description>Reopening of assessment under the income tax law requires tangible material to form a reason to believe that income has escaped assessment. The Delhi High Court held that there was no tangible material to support a belief that the assessees had a dependent agent permanent establishment or a fixed place permanent establishment in India for the relevant years, and therefore the notices issued under section 148 could not be sustained. The Special Leave Petitions were dismissed, with no ground found to interfere with the High Court&#039;s order.</description>
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