2024 (1) TMI 1296

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..... he reasons annexed to the approval u/s 151 of the Act - as stated that these reasons with the approval under Section 151 of the Act was made available to petitioner on 15th February 2022 just a day before the impugned order dated 16th February 2022 disposing petitioner's objections was passed. HELD THAT:- We have also compared the reasons that were made available to petitioner vide communicati .....

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..... he petition is that the reasons provided for reopening, post issuance of notice under Section 148 of the Income Tax Act, 1961 (the Act) (pre 1st April 2021), was incomplete reasons as it appears from the reasons annexed to the approval under Section 151 of the Act. 2 It is stated that these reasons with the approval under Section 151 of the Act was made available to petitioner on 15th February 202 .....

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..... view of the above, the assessment order dated 25th March 2022 also is hereby quashed and set aside. 6 Petitioner shall file detailed objections to the notice dated 31st March 2021 issued under Section 148 of the Act. Should petitioner wish to receive any documents relied upon in the reasons to believe escapement of income, petitioner shall, within two weeks from the date this order being uploaded, .....

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