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    <title>2007 (7) TMI 341 - ITAT DELHI-C</title>
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    <description>The Tribunal allowed the appeal, declaring the reassessment proceedings invalid due to the improper reopening under section 148 after four years, as the assessee had fully disclosed all material facts during the original assessment. The Tribunal found the reopening was based on a change of opinion, which is not permissible. Additionally, the Tribunal deleted the disallowance of Rs. 75,96,534 for previous year expenses, noting that similar expenses had been allowed in prior years and were supported by detailed explanations and documents.</description>
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      <link>https://www.taxtmi.com/caselaws?id=64356</link>
      <description>The Tribunal allowed the appeal, declaring the reassessment proceedings invalid due to the improper reopening under section 148 after four years, as the assessee had fully disclosed all material facts during the original assessment. The Tribunal found the reopening was based on a change of opinion, which is not permissible. Additionally, the Tribunal deleted the disallowance of Rs. 75,96,534 for previous year expenses, noting that similar expenses had been allowed in prior years and were supported by detailed explanations and documents.</description>
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      <pubDate>Fri, 13 Jul 2007 00:00:00 +0530</pubDate>
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