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    <title>2008 (2) TMI 464 - ITAT DELHI-G</title>
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    <description>The Tribunal found that the notice issued under section 148 of the IT Act, 1961, based on a change of opinion and an audit report, was not legally sustainable. The reassessment proceedings were initiated after the expiry of the relevant assessment year and were quashed. The appeal filed by the assessee was allowed, overturning the decision of the CIT(A) and upholding that the excess deduction granted was not due to a change of opinion but a detection of excess deduction.</description>
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