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    <title>2014 (12) TMI 91 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the reassessment proceedings initiated by the Assessing Officer were invalid as they were based on a mere change of opinion without any new tangible material. Consequently, the notice issued under section 148 was quashed, and the appeal filed by the assessee was allowed for statistical purposes. The Tribunal did not consider the second ground of the appeal, as it became academic due to the invalidation of the reassessment proceedings.</description>
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      <description>The Tribunal held that the reassessment proceedings initiated by the Assessing Officer were invalid as they were based on a mere change of opinion without any new tangible material. Consequently, the notice issued under section 148 was quashed, and the appeal filed by the assessee was allowed for statistical purposes. The Tribunal did not consider the second ground of the appeal, as it became academic due to the invalidation of the reassessment proceedings.</description>
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