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    <title>2012 (3) TMI 260 - BOMBAY HIGH COURT</title>
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    <description>The court ruled in favor of the petitioner, quashing the notice issued under Section 148 of the Income Tax Act, 1961. The reopening of the assessment was deemed impermissible as it was based on a change of opinion rather than new evidence, and there was no failure to disclose material facts fully and truly. The court emphasized the petitioner&#039;s entitlement to exemption under Section 10(23B) for the development of khadi and village industries, noting compliance with relevant conditions. The ruling was in favor of the petitioner, with costs not awarded.</description>
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      <description>The court ruled in favor of the petitioner, quashing the notice issued under Section 148 of the Income Tax Act, 1961. The reopening of the assessment was deemed impermissible as it was based on a change of opinion rather than new evidence, and there was no failure to disclose material facts fully and truly. The court emphasized the petitioner&#039;s entitlement to exemption under Section 10(23B) for the development of khadi and village industries, noting compliance with relevant conditions. The ruling was in favor of the petitioner, with costs not awarded.</description>
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