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    <title>2026 (7) TMI 436 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under Sections 147 and 148 was considered sustainable where tangible material indicated undisclosed investment in immovable property and unexplained cash payment, and the original return had only been processed under Section 143(1). Disclosure of the property transaction in a wealth tax return did not amount to disclosure of the source of funds for income-tax purposes. The matter was treated as falling within Explanation 2(b) to Section 147 because income chargeable to tax was seen as having escaped assessment. Prior approval under Section 151 was treated as duly obtained where the Principal Commissioner recorded sanction on the reasons proposed by the Assessing Officer.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794550</link>
      <description>Reassessment under Sections 147 and 148 was considered sustainable where tangible material indicated undisclosed investment in immovable property and unexplained cash payment, and the original return had only been processed under Section 143(1). Disclosure of the property transaction in a wealth tax return did not amount to disclosure of the source of funds for income-tax purposes. The matter was treated as falling within Explanation 2(b) to Section 147 because income chargeable to tax was seen as having escaped assessment. Prior approval under Section 151 was treated as duly obtained where the Principal Commissioner recorded sanction on the reasons proposed by the Assessing Officer.</description>
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