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    <title>1988 (6) TMI 84 - ITAT JAIPUR</title>
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    <description>The Appellate Tribunal held that the reopening of the assessment under section 147 was not justified as all relevant facts were disclosed during the original assessment. The Tribunal emphasized that if primary facts were disclosed initially, there should be no basis for reopening the assessment based on subsequent findings. Consequently, the Tribunal allowed the appeal, ruling in favor of the assessee and concluding that the reassessment was unwarranted. The issue of the profit rate discrepancy was not addressed further due to the invalidity of the reopening itself.</description>
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      <title>1988 (6) TMI 84 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=68063</link>
      <description>The Appellate Tribunal held that the reopening of the assessment under section 147 was not justified as all relevant facts were disclosed during the original assessment. The Tribunal emphasized that if primary facts were disclosed initially, there should be no basis for reopening the assessment based on subsequent findings. Consequently, the Tribunal allowed the appeal, ruling in favor of the assessee and concluding that the reassessment was unwarranted. The issue of the profit rate discrepancy was not addressed further due to the invalidity of the reopening itself.</description>
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      <pubDate>Tue, 14 Jun 1988 00:00:00 +0530</pubDate>
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