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Corporate TaxArticle·7 September 2026

Reopening of wrong foundational facts cannot Be Cured by Sanction

By J the App

Executive Summary

The reassessment was based on reasons that proceeded on materially incorrect facts and did not establish the statutory basis for reopening beyond four years. ITAT held that although the Principal Commissioner was competent to grant sanction, the approval could not cure defective reasons or substitute for meaningful application of mind.

Domain | Corporate Tax | DT

The Position

The assessee's assessment...

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