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    <title>1985 (3) TMI 119 - ITAT JABALPUR</title>
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    <description>Where the reassessment proposal was based on an issue already scrutinised in the original assessment, reopening on the same material was treated as a mere change of opinion and was held invalid because the sanction proceeded on an incorrect factual foundation. The note also states that interest on compensation for acquired land accrued when the court decree awarding compensation was passed, so it did not fall in the assessment year under appeal and was not taxable there. The result described is complete relief to the assessee, with both the reopening and the interest addition failing.</description>
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    <pubDate>Fri, 01 Mar 1985 00:00:00 +0530</pubDate>
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      <title>1985 (3) TMI 119 - ITAT JABALPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=67379</link>
      <description>Where the reassessment proposal was based on an issue already scrutinised in the original assessment, reopening on the same material was treated as a mere change of opinion and was held invalid because the sanction proceeded on an incorrect factual foundation. The note also states that interest on compensation for acquired land accrued when the court decree awarding compensation was passed, so it did not fall in the assessment year under appeal and was not taxable there. The result described is complete relief to the assessee, with both the reopening and the interest addition failing.</description>
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      <pubDate>Fri, 01 Mar 1985 00:00:00 +0530</pubDate>
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