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    <title>2013 (11) TMI 182 - ITAT DELHI</title>
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    <description>The Tribunal upheld the decision of the Commissioner of Income-tax (Appeals), quashing the reassessment proceedings initiated under Section 147/143(3) of the Income-tax Act, 1961. It was found that the reassessment was invalid as there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. The Tribunal concluded that the reassessment was based on a change of opinion, which is not permissible under the law. Consequently, the appeal by the Revenue challenging the quashing of the assessment proceedings was dismissed.</description>
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      <title>2013 (11) TMI 182 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=239005</link>
      <description>The Tribunal upheld the decision of the Commissioner of Income-tax (Appeals), quashing the reassessment proceedings initiated under Section 147/143(3) of the Income-tax Act, 1961. It was found that the reassessment was invalid as there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. The Tribunal concluded that the reassessment was based on a change of opinion, which is not permissible under the law. Consequently, the appeal by the Revenue challenging the quashing of the assessment proceedings was dismissed.</description>
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      <pubDate>Fri, 08 Feb 2013 00:00:00 +0530</pubDate>
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