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    <title>2026 (6) TMI 991 - CALCUTTA HIGH COURT</title>
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    <description>Prosecution sanction under the Income-tax Act was held vulnerable where the assessee&#039;s reply to the show-cause notice was not properly considered and no reasons were recorded for rejecting the explanation. The sanction order was treated as perfunctory, showing non-application of mind and inadequate adjudication of the defence raised. On that basis, writ interference was warranted under Article 226, and the sanction under Section 279(1) was quashed. The matter was remitted for fresh consideration of the reply and for passing of a reasoned order after hearing the assessee.</description>
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      <description>Prosecution sanction under the Income-tax Act was held vulnerable where the assessee&#039;s reply to the show-cause notice was not properly considered and no reasons were recorded for rejecting the explanation. The sanction order was treated as perfunctory, showing non-application of mind and inadequate adjudication of the defence raised. On that basis, writ interference was warranted under Article 226, and the sanction under Section 279(1) was quashed. The matter was remitted for fresh consideration of the reply and for passing of a reasoned order after hearing the assessee.</description>
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