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    <title>2014 (6) TMI 724 - ALLAHABAD HIGH COURT</title>
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    <description>Reopening of assessment is permissible where the assessing authority has relevant material giving rise to a rational belief that turnover escaped assessment or that an exemption was wrongly allowed. At the initiation stage, the writ court does not test the sufficiency of that material. Here, recorded CDs were not separately disclosed in the return or during assessment, and the specific question whether they were covered by the eligibility certificate had not been examined earlier. As no opinion on that issue had been formed in the original assessment, the reassessment notice was not barred as a mere change of opinion, and the challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=248820</link>
      <description>Reopening of assessment is permissible where the assessing authority has relevant material giving rise to a rational belief that turnover escaped assessment or that an exemption was wrongly allowed. At the initiation stage, the writ court does not test the sufficiency of that material. Here, recorded CDs were not separately disclosed in the return or during assessment, and the specific question whether they were covered by the eligibility certificate had not been examined earlier. As no opinion on that issue had been formed in the original assessment, the reassessment notice was not barred as a mere change of opinion, and the challenge failed.</description>
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      <pubDate>Fri, 02 May 2014 00:00:00 +0530</pubDate>
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