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    <title>2010 (11) TMI 884 - ALLAHABAD HIGH COURT</title>
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    <description>Reassessment is impermissible where the original assessment had already examined the relevant material and the reopening is based only on a change of opinion; on that basis, reassessment for 1999-2000 and 2000-01 was held invalid and quashed. Where the earlier assessment did not show consideration of the material forming the basis of reopening, reassessment may be sustained; on that basis, reopening for 1998-99 was upheld and allowed to continue. The operative principle is that reassessment must rest on a legally relevant basis and cannot be founded merely on reconsideration of an issue already decided on the same material.</description>
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    <pubDate>Mon, 01 Nov 2010 00:00:00 +0530</pubDate>
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      <title>2010 (11) TMI 884 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=165432</link>
      <description>Reassessment is impermissible where the original assessment had already examined the relevant material and the reopening is based only on a change of opinion; on that basis, reassessment for 1999-2000 and 2000-01 was held invalid and quashed. Where the earlier assessment did not show consideration of the material forming the basis of reopening, reassessment may be sustained; on that basis, reopening for 1998-99 was upheld and allowed to continue. The operative principle is that reassessment must rest on a legally relevant basis and cannot be founded merely on reconsideration of an issue already decided on the same material.</description>
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      <pubDate>Mon, 01 Nov 2010 00:00:00 +0530</pubDate>
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