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    <title>2014 (11) TMI 67 - ITAT KOLKATA</title>
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    <description>Reassessment under sections 147 and 148 was invalid because the reopening relied on the same cash purchase details already furnished during the original section 143(3) assessment. As the reasons recorded were based on material already before the Assessing Officer, no fresh tangible material existed to justify a belief that income had escaped assessment. Reopening on identical material amounted to a mere change of opinion, which is impermissible under settled law. The reassessment proceedings were therefore quashed and the matter was decided in favour of the assessee.</description>
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      <title>2014 (11) TMI 67 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=252750</link>
      <description>Reassessment under sections 147 and 148 was invalid because the reopening relied on the same cash purchase details already furnished during the original section 143(3) assessment. As the reasons recorded were based on material already before the Assessing Officer, no fresh tangible material existed to justify a belief that income had escaped assessment. Reopening on identical material amounted to a mere change of opinion, which is impermissible under settled law. The reassessment proceedings were therefore quashed and the matter was decided in favour of the assessee.</description>
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      <pubDate>Tue, 14 Oct 2014 00:00:00 +0530</pubDate>
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