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    <title>2015 (7) TMI 297 - GUJARAT HIGH COURT</title>
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    <description>The court held that the reopening of assessments beyond 4 years lacked valid grounds as there was no failure to disclose material facts by the assessee, rendering it illegal. Reopening within 4 years based on excess cane payment was deemed a change of opinion, impermissible under Supreme Court precedent. The court emphasized that all material facts must be disclosed, and reopening based on subsequent judgments or borrowed satisfaction is invalid. Specific grounds for reopening were also rejected as they had been adequately addressed in the original assessments. The court quashed the notices for reopening and stressed adherence to statutory requirements and judicial principles.</description>
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    <pubDate>Fri, 12 Jun 2015 00:00:00 +0530</pubDate>
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      <title>2015 (7) TMI 297 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=261336</link>
      <description>The court held that the reopening of assessments beyond 4 years lacked valid grounds as there was no failure to disclose material facts by the assessee, rendering it illegal. Reopening within 4 years based on excess cane payment was deemed a change of opinion, impermissible under Supreme Court precedent. The court emphasized that all material facts must be disclosed, and reopening based on subsequent judgments or borrowed satisfaction is invalid. Specific grounds for reopening were also rejected as they had been adequately addressed in the original assessments. The court quashed the notices for reopening and stressed adherence to statutory requirements and judicial principles.</description>
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      <pubDate>Fri, 12 Jun 2015 00:00:00 +0530</pubDate>
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