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Court Reviews Reopening of Tax Assessment Due to Search Conducted on Third Party, Not Petitioner, u/s 132.

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....Validity of Reopening of assessment - accommodation entry - Tthe search and seizure action under Section 132 of the Act was not carried out against the petitioner; such action was carried out against a third party - There seems to be weight in the submission made on behalf of the petitioner that the CBDT via its circular dated 01.08.2022 and 22.08.2022 has relaxed the rigour of the law. - CBDT has read into the provisions of 148A and Section 148 of the Act, the principles of natural justice. - HC....

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