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    <title>1981 (4) TMI 167 - ITAT MADRAS-C</title>
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    <description>Reassessment under Section 147(b) was held unsustainable where the assessee had already disclosed the interest expenditure and its treatment in the original assessment, and the reopening rested only on an audit view that the expense could not form part of cost of acquisition. The material relied on by the department was already on record, so there was no fresh information to justify jurisdiction. The issue was at most debatable and the reopening amounted to a change of opinion rather than valid reassessment. The ITAT Madras-C therefore upheld the finding that the reassessment was without jurisdiction.</description>
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    <pubDate>Sat, 04 Apr 1981 00:00:00 +0530</pubDate>
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      <title>1981 (4) TMI 167 - ITAT MADRAS-C</title>
      <link>https://www.taxtmi.com/caselaws?id=70206</link>
      <description>Reassessment under Section 147(b) was held unsustainable where the assessee had already disclosed the interest expenditure and its treatment in the original assessment, and the reopening rested only on an audit view that the expense could not form part of cost of acquisition. The material relied on by the department was already on record, so there was no fresh information to justify jurisdiction. The issue was at most debatable and the reopening amounted to a change of opinion rather than valid reassessment. The ITAT Madras-C therefore upheld the finding that the reassessment was without jurisdiction.</description>
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      <pubDate>Sat, 04 Apr 1981 00:00:00 +0530</pubDate>
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