2024 (8) TMI 372

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..... tion of mind by AO or not? - As decided by HC [ 2023 (3) TMI 987 - GUJARAT HIGH COURT] AO without any conviction, when has issued the notice, this surely is not a case where the reopening of the case is on the basis of any factual error pointed out by the audit party - no material worth the name emerging that to indicate any independent application of mind could be noticed. On the contrary, there .....

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