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    <title>2004 (7) TMI 328 - ITAT LUCKNOW</title>
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    <description>The reassessment proceedings initiated under section 147 of the Income Tax Act were deemed illegal by the Tribunal due to the lack of valid material justifying the belief that income had escaped assessment. The additions made in the re-assessment order were invalidated as they were not supported by new evidence but rather constituted a mere change of opinion. Consequently, the reassessment order was canceled, and all appeals by the assessee were allowed.</description>
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      <description>The reassessment proceedings initiated under section 147 of the Income Tax Act were deemed illegal by the Tribunal due to the lack of valid material justifying the belief that income had escaped assessment. The additions made in the re-assessment order were invalidated as they were not supported by new evidence but rather constituted a mere change of opinion. Consequently, the reassessment order was canceled, and all appeals by the assessee were allowed.</description>
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