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    <title>2026 (5) TMI 994 - ITAT DELHI</title>
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    <description>Furnishing reassessment reasons after issuance of notice under section 148 does not invalidate reopening where the Assessing Officer had already recorded the reasons to believe before the notice was issued, because the later supply of reasons only reflects compliance with reassessment procedure. A challenge to reassessment for want of approval under section 151 also fails where the assessee cannot place the approval on record or otherwise establish its absence. On these principles, both additional grounds to reopen the assessment were rejected, and the reassessment challenge did not succeed.</description>
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      <description>Furnishing reassessment reasons after issuance of notice under section 148 does not invalidate reopening where the Assessing Officer had already recorded the reasons to believe before the notice was issued, because the later supply of reasons only reflects compliance with reassessment procedure. A challenge to reassessment for want of approval under section 151 also fails where the assessee cannot place the approval on record or otherwise establish its absence. On these principles, both additional grounds to reopen the assessment were rejected, and the reassessment challenge did not succeed.</description>
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