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    <title>1998 (10) TMI 100 - ITAT NAGPUR</title>
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    <description>Reassessment under section 147 was examined in light of the post-1 April 1989 amendment, under which the Assessing Officer needs only reason to believe that income has escaped assessment. The earlier, stricter requirement tied to full and true disclosure was treated as governing the pre-amendment regime, so the assessee&#039;s reliance on that law was misplaced. On the facts, reopening could not be rejected merely as a change of opinion on the same material. Reopening under section 147 was therefore justified, and the matter was remitted for consideration on merits by the first appellate authority.</description>
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      <title>1998 (10) TMI 100 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=70827</link>
      <description>Reassessment under section 147 was examined in light of the post-1 April 1989 amendment, under which the Assessing Officer needs only reason to believe that income has escaped assessment. The earlier, stricter requirement tied to full and true disclosure was treated as governing the pre-amendment regime, so the assessee&#039;s reliance on that law was misplaced. On the facts, reopening could not be rejected merely as a change of opinion on the same material. Reopening under section 147 was therefore justified, and the matter was remitted for consideration on merits by the first appellate authority.</description>
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      <pubDate>Fri, 30 Oct 1998 00:00:00 +0530</pubDate>
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