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    <title>2012 (7) TMI 619 - ITAT MUMBAI</title>
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    <description>The tribunal held that the reopening of the assessment was invalid as there was no failure on the part of the assessee to disclose necessary details, and it was considered a mere change of opinion by the Assessing Officer. The appeal filed by the assessee was allowed, and the Revenue&#039;s appeal was dismissed. The tribunal also corrected the restriction of the claim under Section 10B by including foreign exchange realization in the total turnover.</description>
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      <description>The tribunal held that the reopening of the assessment was invalid as there was no failure on the part of the assessee to disclose necessary details, and it was considered a mere change of opinion by the Assessing Officer. The appeal filed by the assessee was allowed, and the Revenue&#039;s appeal was dismissed. The tribunal also corrected the restriction of the claim under Section 10B by including foreign exchange realization in the total turnover.</description>
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