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    <title>2011 (9) TMI 171 - BOMBAY HIGH COURT</title>
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    <description>The Court held that the reopening of the assessment was invalid as it was based on a change of opinion without tangible material justifying it. The notice issued under Section 148 of the Income Tax Act, 1961 was set aside, ruling in favor of the Petitioner. The Court found that the necessary conditions for reopening the assessment were not met, and no costs were awarded.</description>
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      <description>The Court held that the reopening of the assessment was invalid as it was based on a change of opinion without tangible material justifying it. The notice issued under Section 148 of the Income Tax Act, 1961 was set aside, ruling in favor of the Petitioner. The Court found that the necessary conditions for reopening the assessment were not met, and no costs were awarded.</description>
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