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2022 (3) TMI 1388
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....Soumya Singh, Advocate and Mr. Sumit Lalchandani, Advocate. For the Respondent : Satya Pal Jain. ORDER Inter alia contends that the exercise of reopening in the present case is not in consonance with the instructions dated 04.03.2021 issued by the CBDT and further clarified on 12.03.2021 (Annexure P-15) inasmuch as the prior approval of the Chief Commissioner, Income tax had not been accorded. ....